1st June 2015 is the deadline for manufacturers to update all their MSDS to SDS and today, just a few days away from the deadline, we thought it would be useful to share some our thoughts about the importance of SDS in REACH and the need for its updation.
SDS and its importance in REACH
REACH Regulation has been implemented by European Union to control the use of hazardous substances in the EU market for protecting human health and the environment. REACH obligates everyone in the supply chain to communicate freely about the substances they use, particularly with respect to substances that can cause any hazards to human health and the environment. REACH mandates this communication to occur through the supply chain both upstream and downstream.
To enable free flow of communication between suppliers and downstream users in all stages of the REACH process Safety Data Sheets (SDS) are used. Since SDS is the vital component of GHS, they are intended to provide all necessary information about physical and chemical data of a substance/mixture for its safe use in any application. To maintain their products in the EU market, manufacturers, importers, distributors, and downstream users must make sure that their SDS for substances and mixtures comply with the requirements of REACH.
As per GHS, an SDS should be prepared for substances and mixtures which meet the criteria for physical, health or environmental hazards. SDS should also be prepared for all mixtures that contain carcinogenic, mutagenic or toxic to reproduction elements in concentrations exceeding the threshold limit specified for SDS.
In such cases of preparation of SDS, the following should be included:
- Information about the properties of the substance/ mixture
- Information on its hazards
- Instructions for transport
- Safety measures- instructions for safe use, disposal and exposure control
This information should be included in the main body of SDS or in the section for additional exposure scenarios.
In case there is a requirement to provide an SDS, it must be provided free of charge to anyone who has received or requested an SDS. SDS can be provided on paper or electronically. SDS should be provided either before or at the time of first delivery of the substance or mixture.
The SDS should be immediately updated if new information on hazards or risk management measures is made available. SDS must be updated as early as possible when:
- Any latest information on hazards becomes available
- Any latest information on risk management measures becomes available
- Details of authorizations granted or refused
- Details of any restrictions imposed
SDS issued after registration must also include the registration number.
With GHS alignment, each package of a classified hazardous chemical should be labeled or marked with the following elements:
- Product or chemical identifier that matches the product or chemical identifier on the SDS
- Contact information of the product or chemical supplier
- Hazard Pictograms
- Signal words
- Hazard statements
- Precautionary information
Transition of Material Safety Data Sheet (MSDS) to Safety Data Sheet (SDS)
Material safety data sheet (MSDS), which OSHA (Occupational Safety and Health Administration) calls a “one-stop resource for everything you might need or want to know about a chemical”, is the cornerstone of OSHA’s Hazard Communication Standard (HCS). OSHA revised the HCS to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) to help manage the risks associated with chemicals in the workplace with the help of the new SDS. The intention behind GHS is to harmonize classification criteria and hazard communication tools at regional, national, and worldwide level. Due to this, OSHA adopted United Nations’ GHS and brought substantial changes to MSDS. This led to the formulation of SDS.OSHA further decided to standardize the 16 section format with a required ordering of sections for SDS as a mandate. Hence, REACH SDS now includes these rules that are in line with GHS to help manage the risks associated with chemicals. Annex II of the REACH Regulation provides the detailed requirements and format of SDS for substances and mixtures.
Over the past 3 years UN’s GHS format for SDS has received global acceptance, leading to implementation of GHS in the European Union and Asian manufacturing nations like Korea, China and Japan.
SDS was formerly named as MSDS (Material Safety Data Sheet) which was functionally equivalent to the new SDS with a slight format change in the template and content. Below mentioned are a few details about the transition of MSDS. GHS formatted SDS and ANSI Standard 16-section MSDS are nearly identical. One of the major changes is the ‘renaming of material safety data sheets from MSDS to SDS.
The other major changes are:
1. As per GHS requirements SDS has a reclassified order for the standard 16 sections. The new order is mentioned below.
- Hazard(s) Identification
- Composition/Ingredient Information
- First-Aid Measures
- Fire-Fighting Measures
- Accidental Release Measures
- Handling and Storage
- Exposure Control/Personal Protection
- Physical & Chemical Properties
- Stability & Reactivity
- Toxicological Information
- Ecological Information
- Disposal Considerations
- Transport Information
- Regulatory Information
- Other Information
An SDS needs all 16 sections completed in the above order to become GHS-compliant SDS.
- SDS needs to represent the hazardous effects of the substance with the use of GHS standard pictograms
- Inclusion of key words and phrases in the SDS, standardized by GHS
- Introduction of new GHS labels
- Need for conducting updated employee trainings
Important dates to remember:
Manufacturers need to keep track on the following dates to be able to execute successful REACH compliance for their products, in lines with the upgraded version of GHS-SDS.
- Employers must educate employees on the updated information by December 2013.
- Manufacturers must update all the MSDS to SDS by June 2015.
- Employers and end users must have the new GHS-compliant SDS in their workplace for their chemicals by June 2016.
Manufacturers should be well prepared by now to replace all of their MSDS with GHS formatted SDS in the next couple of months.
By June 1, 2015, Chemical manufacturers and distributors are expected to complete their reclassification of chemicals and should start the shipping of GHS formatted SDS and labels with their delivery. MSDS database should be updated to GHS formatted SDS database within the same time period.
Despite no official confirmation from EU, manufacturers have some respite in case they share the SDS documents within 1st June 2015. As per a reputed agency document EU will continue to allow the SDS (as per old standards) for the next 2 years, if the SDS was shared by the manufacturer before 1st June 2015. This provides more time to the chemical manufacturers for sharing the GHS formatted SDS with their customers. But to avoid last minute filings and to obtain easy access to US, European and Asian markets its suggested to get the SDS refreshed as early as possible.
SDS will continue to be the backbone of hazard data communication irrespective of being called MSDS or SDS. Manufacturers who can foresee the future and take proactive implementation can make MSDS to SDS transition an easier job as the dead line approaches.