What does the expertise for safety data sheets include?

The preparation of safety data sheets (SDS) requires expertise in safety data sheets. This is completely independent of the method and software used to create the SDS. But what does this expertise mean and who needs it at all? The law is very general here, but there are sources with more detailed information about the expertise.

Expertise for safety data sheets according to REACH regulation

Nevertheless, let’s start with the legal requirements. In the REACH Regulation, Annex II, Part A, 0.2.3, the following text is given:

“[…] The safety data sheet shall be prepared by a competent person who shall take into account the specific needs and knowledge of the user audience, as far as they are known. Suppliers of substances and mixtures shall ensure that such competent persons have received appropriate training, including refresher training.”

It is therefore required, that the safety data sheet is expertly prepared and that application-specific features are also taken into account. In other words, knowledge about the preparation is needed, as well as knowledge of the use and special requirements of the users of the product for which the safety data sheet is being prepared.

Additional information from ECHA guidelines

The guidelines on safety data sheet preparation (for details see “Sources”) provide additional guidance:

The “competent person” does not have to be a single individual. The necessary knowledge for compiling the safety data sheets can also be distributed among several people. Furthermore, the competent person(s) can also take on a coordinating role.

In general, it is recommended to document the process of SDS creation and updating.

It is recommended to attend appropriate training courses. With training certificates and refresher visits it is simply easier to prove compliance with the legal requirements (expertise and refreshers / continuous training). Corresponding courses are also regularly offered in Europe by various bodies.

Content of the expertise

In principle, you need knowledge of everything that is necessary for writing your own safety data sheets. Here, too, a list of the guidelines will help. I only mention a few points here that are generally useful. For details, you can consult the guidelines or relevant training seminars.

• European regulations and directives – to a certain extent, it is self-explanatory that knowledge of the legal situation is essential for legally secure drafting.
• It is also important to have an idea of which legal areas are particularly relevant for one’s own preparation (e.g. biocidal products, detergents and cleaning agents, …).
• National legislation – in addition to the European requirements, each European member state also has its own requirements for the preparation of safety data sheets. Typical examples are the storage class and water hazard class in Germany.
• Sector-specific guidance documents – especially good for covering the requirements and knowledge of the user group.
• Knowledge of chemical naming rules, to designate the product identifier correctly.
• Information on the individual sections of the safety data sheet, such as knowledge of toxicology, first aid measures, accident prevention, transport and others.

Often, courses also describe the order in which it makes sense to prepare safety data sheets.

Sources:

Regulation (EC) No 1907/2006 (REACH Regulation), consolidated version of 27.02.2020

Guidance on the compilation of safety data sheets, version 3.1 (German), European Chemicals Agency 2015, ISBN 978-92-9247-514-7.