Making Safety Data Sheets
Douglas Mowat, Chemical Exchange Directory S.A.
Previous Focus and Editorial articles have discussed legislation on working with Chemicals and Hazardous Substances in Europe. This article deals with a practical example and concerns making Safety Data Sheets (SDS) for chemicals.
The SDS has a very important role in the chemical market. It is the simplest way for suppliers and their customers to exchange essential safety and environmental information. A well constructed SDS reflects the image of the supplying company, conveying an impression of competence and helps to build confidence between the parties. All suppliers of hazardous substances and preparations in the European Union are obliged to make SDS available for these products. In addition, many companies have SDS for all of their products, even those which are not classified as dangerous as their customers regularly ask for an SDS for everything.
Even when a supplier has SDS exist for most of his products, there are still many cases when a new SDS has to be made. Typical examples are for new products or more often for new mixtures. Often, the SDS is needed quickly and the safety specialist has to find reliable information with the minimum delay.
Making an SDS is a specialised subject, but fortunately there are good sources of assistance for both experienced and inexperienced personnel. The basic requirements on the contents of an SDS are published in European Directives 91/155/EEC and 93/112/EEC, both of which can be found on SilverPlatter's OSH-CD product, as well as other guidance such as Safety data sheets for substances and preparations dangerous for supply. The 16 Sections of the SDS are as follows:
- IDENTIFICATION OF THE SUBSTANCE/PREPARATION AND THE COMPANY/UNDERTAKING
- COMPOSITION/INFORMATION ON INGREDIENTS
- HAZARDS IDENTIFICATION
- FIRST AID MEASURES
- FIRE-FIGHTING MEASURES
- ACCIDENTAL RELEASE MEASURES
- HANDLING AND STORAGE
- EXPOSURE CONTROLS / PERSONAL PROTECTION
- PHYSICAL AND CHEMICAL PROPERTIES
- STABILITY AND REACTIVITY
- TOXICOLOGICAL INFORMATION
- ECOLOGICAL INFORMATION
- DISPOSAL CONSIDERATIONS
- TRANSPORT INFORMATION
- REGULATORY INFORMATION
- OTHER INFORMATION
The most important step is deciding if the product has dangerous properties which require it to be classified, both for supply and for transport. This may require the use of special labels and symbols along with Risk Phrases and Safety Phrases.
The EU has published a list of dangerous substances for supply, often referred to as Annex 1 (of Directive 67/548/EC), for which classification and labelling requirements are pre-defined. The Hazards Identification in Section 3 of the SDS and the Legislation Information in Section 15 are normally derived from the information in Annex 1. A full list of these dangerous substances is in the EINECS-Plus product, jointly published by SilverPlatter and the European Union Publications Office. The remaining Sections of the SDS are then completed by taking into account the dangerous properties, flammability, toxicology and environmental properties etc.
When a product is not listed in Annex 1, the supplier must still make sure that it is permitted to be sold in the EU market and that it does not have properties which require a hazardous classification. The first step is to ensure that the substance or the ingredients of a mixture are existing substances on the EU market. This information can be found in the EINECS lists, (available in EINECS-Plus). If it is not on the EINECS list, the substance will have to be notified to a competent authority in the country where the product will be sold, a process which can be both costly and time consuming. Placing unlisted products on the market can result in significant penalties.
Assuming the substance is in EINECS, the next step is to decide if it needs to be classified. This requires knowledge of the classification procedure. The EU Substances Directive, 67/548/EC (and its subsequent amendments) contains several Annexes to assist with this. Annex VI is a guideline on classification of substances, and Directive 88/378/EEC and its subsequent amendments is the equivalent for mixtures. Full texts of both these Directives are included in EINECS- Plus as well as graphics which should be used in datasheets and labels plus useful lists of definitions of Risk and Safety phrases.
The acute toxicity, ecotoxicology and flammability properties of the product must be know to be able to decide if classification is necesasary. In the ideal situation, test reports are available, and the procedure is relatively simple. However, if there is no test data, the supplier has to find other sources, or initiate testing.
The RTECS databank from the US NIOSH Agency contains toxicology information on more than 100,000 substances and is one of the best recognised sources of such data. The HSDB databank from the US National Library of Medicine also contains toxicity data but in addition has, flammability (flash points), some ecotoxicology information and also safety guidance for handling and storage. Both RTECS and HSDB are on SilverPlatter's CHEM-BANK product and the information is updated regularly.
Using data from the above sources, it is possible to complete sections 3, 4, 5, 6, 7, 8, 10, 11, 12 and 15 on the SDS. Sections 1, 2 and 9 are dependent on the supplier and the product. The remaining Sections, 13 and 14 again require specialist knowledge. Section 13 concerns the safe disposal of the product and its packaging. Information to assist in completing this section can be found in SilverPlatter's Environment Plus product which contains the full text of the environment related Directives of the Council of the European Communities plus other authoritative advice and guidance. For Section 14, it is necessary to consult the UN Recommendations on the Transport of Dangerous Goods, or the more detailed regulations for road (ADR), Rail (RID), ocean (IMO) or air (ICAO/IATA).
Using data from these products, it is possible to make a good English language SDS following the 16 section European Union format.
The above text is an illustration of how the SilverPlatter Health & Safety Publishing Group's product range can help chemical suppliers in producing safety data sheets.
The products mentioned in this article are available for a free trial.
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