There can be a long supply chain between the raw materials and finished products in the chemical industry, in which the existing materials are also processed further. Every safety data sheet summarises all the information that has to be transferred along this supply chain. But understandably, not everyone is fully familiar with everything. Have you ever played “Chinese whispers”? A lot of the information does not reach the final recipient. The problem and the entertainment value arise from the restricted communication. What can be a source of great amusement in the game should not happen with safety data sheets. This is why it is not only useful to communicate outside the safety data sheet, but also to critically examine the existing information in order to maintain the quality of all safety data sheets.
Participants in the supply chain
A lot can happen along the way. First, raw materials are produced or imported. These substances are processed further or added to mixtures for certain properties. These mixtures can in turn be part of other mixtures (MiM). But manufacturers, recipients and consumers do not always find each other straight away. There are also different types of distributors and stockists. And products can be refilled and sold on under a different name, perhaps even in other countries.
Distribution of roles along the supply chain
Manufacturers, importers and refillers are expected to supplement this information when creating their own safety data sheets and also transmit this to their suppliers if it includes relevant findings. Distributors and stockists in turn have the task of passing on the existing information from their suppliers to their recipients in the form of safety data sheets. But communication in the other direction can also be crucial: The customer of the distributor/stockist may have obligations under REACH and therefore has to contact the creator of the safety data sheet. For example, to transfer a new, identified use. In the coming weeks, I will go into more detail on the differences between distributors and downstream users as well as their respective obligations.
Conclusion
Be aware of the scope of the information flow and its potential for error if you notice something that may be incorrect in a safety data sheet. It is also important that you understand your role under REACH and do not obstruct the information flow. If you do notice something, please share your findings with the creator of the safety data sheet – everyone will profit as a result.
Our support for good safety data sheets
Since the end of 2019, it has been possible to check the classification and labelling in safety data sheets for mixtures free of charge with our SDBcheck. As the information in the PDF files is automatically read out, the process requires little of your time. SDBcheck allows you to perform cross-checks on safety data sheets to dispel any doubts.
Sources:
Regulation (EC) No. 1907/2006 (REACH Regulation), consolidated version, dated 27/02/2020 ECHA guidelines for downstream users, version 2.1 European Chemicals Agency, October 2014, ISBN 978-92-9244-148-7
