What is different in the US-SDS? (Part 2)

After an overview from the first part to the series, I summarize some differences between the European (EU-SDS) and the US Safety Data Sheet (US-SDS) formats. As a source, I primarily use the corresponding legal sources. [1] [2]

Substances and mixtures in the EU-SDS

The CLP Regulation indicates the classification and labeling and identification of substances and mixtures (product identifiers) in the EU-SDS [3]. The information of the ingredients is regulated and partly also harmonized. If a substance is mentioned in Annex VI of the CLP Regulation, then its name, including the corresponding identification numbers, must be used. For these substance names, translations into the official languages of the individual EU member states are therefore also available.

The minimum substances to be indicated in the safety data sheet are determined by their physicochemical hazards, hazards to humans, and aquatic toxicity hazards (the portion of environmental toxicity that has a direct CLP classification). If a substance has at least one of these hazards, the concentration in the mixture determines whether the substance should be mandatory in the safety data sheet. A voluntary indication is always possible.

The classification of the mixture can be found in section 2 of the safety data sheet. If it is a mixture, the classifications of the indicated ingredients can be found in section 3.2. Since the beginning of 2021, specific concentration limits can also be found in this section.

Information in the US-SDS – Focus: Hazard to humans

Similar information can be provided in the US-SDS. However, the focus is clearly on the danger to humans (health hazards). Whether a particular substance has to be listed in the safety data sheet of the mixture is decided on the basis of the hazard to humans and the actual concentration in the mixture. Environmental hazards are not considered as strongly as in the CLP Regulation and thus in the EU-SDS. So it could well be that the US-SDS has different substances in section 3 than the EU SDS when it comes to meeting the minimum requirements.

For toxicity, the picture is similar. While the US CFR 1910.1200, Annex D, is supposed to mention the proportion of substances with unknown acute toxicity, the EU SDS additionally refers to substances with unknown aquatic toxicity.

The focus also continues in the mandatory toxicity information in the US-SDS. While Section 11 (human toxicity) is mandatory in both jurisdictions, Section 12 (environmental toxicity) is optional in the US-SDS.

Conclusion

For the most part, the information on ingredients in the SDS is consistent. Only in the area of environmental toxicology there are differences.

Sources:

[1]        Regulation (EC) Nr. 1907/2006 (REACH)

[2]        OSHA CFR 1910.1200 App D

[3]       CLP-Regulation Nr. 1272/2008

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