When is a safety data sheet up-to-date?

The use and format of safety data sheets (SDS) is specified in the REACH Regulation. It is important to know if a safety data sheet is required and how often it has to be updated.

Do you need to provide a safety data sheet?

An SDS is generally required if a substance or mixture is classified as hazardous under the CLP Regulation (EC) No. 1272/2008; or a substance is persistent, bioaccumulative and toxic (PBT), or very persistent and very bioaccumulative (vPvB), see Article 31 (1) of the REACH Regulation. Article 31 (3) outlines cases where an SDS must be provided upon request. This relates to mixtures that are not classified as dangerous under the CLP Regulation but contain ingredients associated with severe risks.

How often does the SDS need to be updated?

The SDS must be created no later than on the day of the first delivery of the substance or mixture. An update may be required for several reasons. A new SDS containing updated information must be provided without delay as soon as new information on risks or hazards becomes available, once an authorisation has been granted or refused, or once a restriction has been imposed. If the updates have not been recorded elsewhere in the SDS, these can be looked up in Section 16, if interested. This means there is no time-bound obligation to update the SDS. It remains current until new information emerges in accordance with Article 31 (9) of the REACH Regulation. As we all make mistakes, updates may still be required due to corrections.

Sources:

Regulation (EC) No. 1907/2006 (REACH Regulation), status 03/02/2016; Regulation (EC) No. 1272/2008 (CLP), consolidated version status 01/06/2015 This could also be of interest to you: SDBtransfer: Easily transfer safety data sheets

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Philip Stefl
M. Sc. Philip Jorge Stefl (Chemieingenieur), Legal Compliance / Produktentwicklung GeSi³

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