PCN and SDS creation go hand in hand
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Both the European Product Notification (PCN) and the Safety Data Sheet (SDS) provide information on hazards of dangerous substances. But they do this with different objectives. Nevertheless, there are many similarities, which is why the PCN and SDS creation work well together. They even have to be identical in some aspects.
Aim of the safety data sheet
The safety data sheet is an obligation resulting from Title IV of the REACH Regulation [1]. The safety data sheet contains information from the substance registrations of the pure substance manufacturers and further information arising along the supply chain.
The SDS informs both formulators for the creation of their own products from the purchased mixtures and commercial consumers as a basis for their occupational safety.
Aim of the European Product Notification
The PCN is an obligation according to Article 45 of the CLP Regulation [2]. First and foremost, member states should communicate and collect information on hazardous products and pass it on to poison information centres.
In addition, the products are categorised (EuPCS) and may be used for the purpose of analysis to identify needs for improved risk management measures (Article 45, (2), b)).
Shared information
Interestingly, the PCN also requires information that you can find in the safety data sheet. First and foremost, the classification and labelling (section 2), as well as the description of toxicological effects on humans (section 11).
No discrepancies should exist between the safety data sheet and the PCN. Changes in section 11 and thus new / updated findings on toxicity are consequently a reason for updating the PCN. In this case and for similar reasons exists the possibility to update your own PCN (update without significant change of the formulation).
Common ground
Besides the directly shared data, the data basis for mixture safety data sheets and PCNs is the same. Both require accurate formulation data and classification information of the substances and mixtures contained.
The safety data sheet offers greater freedom in this respect in some places. Nevertheless, it also contains more information in other areas, such as disposal and dangerous goods information.
Conclusion
It usually makes sense to automate the creation of safety data sheets, even for a small number. Larger quantities of product SDSs can only be generated and kept up to date using a specialised software. The situation is similar with PCNs – because of the common data source and the partly identical information, it is worthwhile to use the already existing data from the safety data sheet. Re-entering the information via the platform specified by ECHA (IUCLID) is possible, but only rather practicable for smaller amounts of necessary notifications.