If you produce hazardous substances or mixtures, you also have to create safety data sheets (SDS). But who is actually allowed to create these safety data sheets? Which qualifications are required for this? And where can you find information on how to create them?
Information on safety data sheets
Especially when creating safety data sheets, it is always worth looking at the primary source. I would recommend that anyone planning to create safety data sheets should read Annex II of the REACH Regulation (Regulation (EC) No 1907/2006). This provides the requirements and information on the overall creation and the different sections. A much more comprehensive source is the associated ECHA guideline. This is particularly helpful if you need specific information on a certain section.
Legal minimum requirements for the creation of SDS.
The creation of safety data sheets requires expertise (REACH Regulation, Annex II, 0.2.3.). The safety data sheet must be created by expert, trained individuals who also have experience with the circle of users contained in the safety data sheet. This makes sense, since the users of the hazardous substances produced must be informed about how to handle them and the hazards involved. In addition to expertise, refresher training courses also have to be attended.
Is expertise enough?
Expert training courses for the creation of safety data sheets are also offered accordingly. But in my experience, these training courses are not sufficient in order to competently create all sections of the safety data sheet. They provide good insight and a more concrete understanding of what is behind the individual sections of the safety data sheet. But quite a lot of additional research / training is still needed in order to put together a complete safety data sheet. I recommend that expert training courses should be attended as early as possible in the initial training period in order to get a clearer idea of the requirements.
The guideline on the creation of safety data sheets includes the following recommendation: “However, in this context the term [sachkundig] can be defined in such a way that it represents a person (or multiple persons) – or a coordinator of a group of persons – who, based on their training, expertise and continuous further education has sufficient knowledge to create the respective sections of the SDS or the entire SDS.”
The correct framework for SDS creation
There are many requirements regarding the appearance of a safety data sheet and what information has to be mentioned when and where in the safety data sheet. In addition, areas in the safety data sheet are also updated without the influence of the creator, such as dangerous goods data and occupational exposure limit values. If there are larger numbers of safety data sheets, it is impossible to maintain an overview without assistance. This is why the use of specialised software for the creation of safety data sheets is so important – starting with a certain number of safety data sheets, the time saving becomes significant.
Sources: Regulation (EC) No 1907/2006 (REACH Regulation), consolidated version, as of 24/08/2020 Guidance on the compilation of safety data sheets, Version 3.1 (German language version), European Chemicals Agency 2015, ISDBN 978-92-9247-514-7