Another SDS ‘Headache’
If you are supplying chemical products that require Safety Data Sheets (SDS’s) to multiple countries, you are also likely to know this headache well.
With the implementation of the Globally Harmonized System of Classification & Labeling (GHS) around the world progressing, issues are beginning to appear which emphasize points where…. Maybe requirements are not so ‘harmonized’. One such issue, is ingredient disclosure requirements on SDS’s for mixtures across different regions of the world.
The United Nation’s (UN’s) GHS system, does contain some standardized recommendations for SDS, including that SDS’s should be provided only for chemicals classified as ‘hazardous’, SDS’s should contain basic minimum information (e.g., 16 sections with specific headings), as well as more detailed recommended guidance on how to prepare each section of the SDS.
Ingredient disclosure recommendations, in particular, appear in Annex 4 of the GHS. In general, the GHS recommends that for a mixture classified as hazardous, the SDS should list all ‘hazardous’ ingredients, which are individually hazardous to health or the environment, when the ingredients are present above concentration cutoff levels. There’s several parts of that general requirement, which can be viewed as a ‘can of worms’.
Are the cutoff levels the same for each region of the world? How should one handle ingredient disclosure when you are in a region that doesn’t regulate environmental hazards on SDS’s? Are ‘non-hazardous’ chemical mixtures really not Continue Reading…
Isn’t everyone using GHS for SDS’s and labels?
The answer to that is yes, and also no.
The European Union (EU)
In the EU, REACH [Regulation (EC) No. 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals] and GHS regulations [Regulation (EC) No. 1272/2008 on classification, labelling and packaging of substances and mixtures, or the ‘CLP’] have already been implemented for many years. Most phases of the EU’s implementation plan have already been completed. There is one last remaining date that has not yet passed, however, with respect to SDS’s and labels.
SDS’s and labels for pure substances are required to fully compliant with REACH and the CLP. The last transition date for pure substance SDS’s was completed on December 1, 2012. Any SDS and label for a pure substance after that date, had to be fully compliant with REACH and CLP regulations, and display only GHS information.
SDS’s and labels for mixtures, for products placed on the market in the EU for the first time after June 1, 2015, are also required to be fully compliant with REACH and the CLP, and display only GHS information.
Mixture SDS’s and labels, only for products already placed on the market in the EU for the first time before June 1, 2015, however, may still show old system EU information. These SDS’s and labels for mixtures, may still display the EU’s old system Continue Reading…
Training is needed in everything we do. Whether it is work, play or home we are constantly learning or being trained on something. We train our children for adulthood. We train our athletes how to run plays or moves. We are trained at our places of employment on how to do our jobs properly. Training in all aspects of life is in place to help us do things properly, help us succeed and help keep us safe.
In the workplace, how do we know just what type of training we should be getting? Obviously, it is going to change from site to site based on the type of business you work for. Regardless of the type of business, all workplaces are required by the OSH Act to provide a safe place to work. As per OSHA there are relevant types of training needed for different types of industry. These industries listed below with their appropriate regulation could be required:
If an industry doesn’t fall under a specific regulation like construction, they would follow the general industry standard. OSHA just updated their “Training Requirements in OSHA Standards” booklet. In this booklet OSHA gives a guide to all training requirements for employers, safety and health professionals, training directors and others to comply with Continue Reading…
Remember eating alphabet soup as a child? Remember playing with the noodle letters to make more words than your friends or siblings? Remember when the letters would not cooperate and random letters were floating in your bowl? Remember trying to use abbreviations and acronyms to make those random letters work? Oh, the frustration! Working on Safety Data Sheet (SDS) documents in the European Union (EU) can often feel like some of those memories.
ICC Compliance Center is here to help and possibly give some new ways to win in your next competition.
EU – Directives and Regulations
As a reminder, the EU governs hazard communication in two ways – by directives and regulations. Directives mean all member states are required to implement their version of the directive within their state. Regulations, however, mean complete implementation in all member states without the need for or allowance of versions in each state.
Current directives and regulations
As of February 2015, there are multiple active directives and regulations at work in the EU. The oldest is the Dangerous Substances Directive (67/548/EEC) or the DSD and the Dangerous Preparations Directive (1999/45/EC) which is the DPD. This is followed by the Registration, Evaluation, Authorization and Restriction of Chemical Substances Regulation more commonly known as REACH (EC1907/2006). Finally, there is the Regulation on Classifying, Labeling and Packaging of Substances and Mixtures (1272/2008/EU) or in the shortened form the CLP. It should be mentioned Continue Reading…
REACH stands for Registration, Evaluation, Authorization, and restriction of Chemicals. This United Nations (UN) law took effect June 1, 2007 and falls under the ECHA (European Chemicals Agency). REACH requires the registration of approximately 30,000 chemical substances produced in or imported into the European Union (EU). It places greater responsibility on industry to develop information on and manage the risks that chemicals may pose to human health and the environment.
The main goals of REACH are to ensure a high level of protection of human health and the environment from the risks that can be posed by chemicals, the promotion of alternative test methods, and the free circulation of substances on the internal market and enhancing competitiveness and innovation. REACH places the burden of proof on companies. To comply with the regulation, companies must identify and manage the risks linked to the substances they manufacture and market in the EU. They have to demonstrate to ECHA how the substance can be safely used, and they must communicate the risk management measures to the users.
REACH impacts on a wide range of companies across many sectors, even those who may not think of themselves as being involved with chemicals, Including: Chemical Manufacturers, Importers, downstream users (customers) and companies outside the EU. The responsibility for fulfilling the requirements of REACH, such as pre-registration or registration lies with the importers established in Continue Reading…