Deviations that aren’t any – the solution lies in the detail

You already know our online tool SDBcheck^® (Currently only available in German) for checking the plausibility of your safety data sheets from my last blog posts. Today I would like to discuss the situations in which deviations occur that are actually not deviations at all.

Plausibility check with SDBcheck^®

SDBcheck^® is a free online tool with which you can check your supplier safety data sheets for plausibility. In Germany, this is obligatory according to TRGS 400 [1]. SDBcheck^® checks whether the classification and labelling from section 2 match the other information in the SDS, for example the ingredients or toxicity data. You can find the legal basis for this in the CLP Regulation [2]. There, it is specified for each hazard class when a classification into a certain hazard category takes place.

Identified deviations

If the classification of the SDS and the classification determined by SBDcheck® match, the SDS is plausible in these points. However, if you check your SDS, you will also come across deviations again and again. In this case, the classification and labelling determined by SBDcheck® do not match the classification and labelling from section 2 of the checked SDS. If you find a deviation, you should contact the supplier.  This is also stated in TRGS 400. Before you do this, it is worthwhile to pay attention to a few points again. There are also cases where the calculated deviation is none.

Incorrect data transfer

The most common reason for a “wrong” deviation is an error in the data basis. SDBcheck^® reads out your safety data sheet via text recognition. In the comparison screen, it is your task to compare whether the text matches the contents of the SDS. Errors may occur during the read-out, for example because contents are transmitted incorrectly or are missing. You can identify this in the comparison and correct or add to it manually. If, for example, a pH value of 1 is accidentally read out, although the SDS doesn’t state any, this has drastic consequences. An extreme pH value leads directly to a classification in Skin Corr. 1 (Skin Corrosion, Category 1) and Eye Dam. 1 (Serious Eye Damage, Category 1).

Mixture data in section 11

Another reason is that although the mixture classification was calculated correctly from the ingredients, it is omitted for another reason: If measurements on the mixture show that the classification is not necessary, it is omitted. This concerns classifications in the health hazards. For example, if the ingredients classified as skin irritant exceed a limit of 10%, the mixture is also classified as skin irritant (Skin Irrit. 2). However, if e.g. animal tests have shown that the mixture is not irritating to the skin, this trumps the calculated classification. Such measurements and indications are referred to in section 11 of the SDS. So if you notice a deviation, you should always take another look at section 11.

Conclusion

With SDBcheck^® you can check your safety data sheets for plausibility quickly, conveniently and free of charge. Nevertheless, there are some points that you need to consider. This applies in particular if you discover a deviation and want to report it to the supplier. In this case, you should especially check whether an incorrect deviation has not been determined on the basis of the points mentioned.

[1]        Technical Rules for Hazardous Substances, TRGS 400, as of 08.09.2017, BAuA website.

[2]        Regulation (EC) No 1272/2008 (CLP Regulation), consolidated version REACH-CLP-Biocide-Helpdesk (DE), as of 01.03.2022