SDS Check Services

The introduction of REACH and the implementation of the Globally Harmonised System of Classification and Labelling (GHS) will present greater challenges to the recipients and users of Safety Data Sheets, when they attempt to assess or check the quality of their SDS. In view of the fact that a Safety Data Sheet is a key source of information for employers carrying out workplace risk assessments such as COSHH, it is vital that the SDS must contain accurate and up-to-date data and information. The question is: how can a user determine whether or not a Safety Data Sheet from a supplier or manufacturer is accurate and up-to-date?

Many employers and Health & Safety Professionals make the assumption that SDS supplied by the manufacturers and suppliers have been generated accurately and therefore negate the need to carry out a check on their accuracies. Some claim that as they are not chemists, therefore they lack the experience and knowledge to conduct such checks.

When revised SDS are issued by the suppliers, current practice by some SDS users is to conduct basic checks by merely reviewing issue dates and version numbers without making a careful assessment of the revisions. Some take the view that as long as there are revision dates on the SDS, then that ends the quality checks.

Some employers abdicate their responsibility for checking the SDS by adopting the view that the manufacturers and suppliers would be held accountable if the errors found on the SDS were to lead to serious accidents and/or legal action. This is a wrong assumption to make!

The importance of having quality SDS is emphasised by the HSE as the extract4 from the COSHH Regulations states that “accurate, complete and correct information on data sheets is essential when considering workplace controls, e.g. over-classification of a substance might lead to unnecessarily stringent controls, while under-classification may result in risks to employees’ health. If employers have concerns about the quality and reliability of information provided on a data sheet, or if they are unsure of the application of the information to their situation, they should contact the supplier for clarification or for further guidance”.

Using this service, it is first determined whether the product concerned falls within the scope of the CHIP regulations or the CLP Regulation and, if so, the Safety Data Sheet will be assessed against the PRINCIPAL requirements for compliance as follows:

• Compliance with REACH Safety Data Sheet format e.g. correct 16 headings and correctly dated
• For a substance, whether the classification complies with either that contained in Table 3.1 and Table 3.2 of CLP or the toxicological and ecotoxicological data that are quoted on the Safety Data Sheet.
• For a mixture, whether the information about the composition complies with CHIP or CLP and, if so, whether the classification has been determined correctly.
• Whether the substance or substances in a mixture have a reported Occupational Exposure Limit, e.g. WEL in EH40, and, if so, whether it appears correctly on the Safety Data Sheet.
• Whether the labelling information is correct.
• Whether the information in the transport section is consistent with other information provided in the Safety Data Sheet.

In the past, searches on SDS revisions have been mainly carried out on the basis of legislative or regulatory changes. There is a need to look at wider aspects and to develop a simple product information quality and confidence rating system for compliance.

We propose to assign each chemical product with a Confidence Rating Value (CRV). based on the following criteria:

• Confidence Rating by SDS Writing Standards
• Confidence Rating by Information Sources
• Confidence Rating by Date
• Confidence Rating by SDS Data