Safety Data Sheet (SDS) is a document designed to provide persons who handle chemicals with relevant safety information. The main goal of the SDS is to help employers to protect their employees by pointing out and reducing the risks associated with the handling of chemical products. It should help anyone who handles the chemicals protect themselves from the exposure, hazards, or accidents that may arise while handling the chemical product. SDS contains the most important information about the precautionary measures which needs to be followed while working with the chemical product.
This article will go through the most important things that you need to keep in mind when updating and managing Safety Data Sheets.
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When is the update needed?
Manufacturers and suppliers of chemicals and hence SDS’, need to update their SDS’ in case that the new hazard information is available for their chemical product or an update or new regulatory requirement has been issued. This means that they need to constantly lookout for new information about their chemicals and follow any new regulatory changes that apply to the chemical and its SDS. Whenever an SDS has been updated, it needs to be provided with the next order or shipment following an update. Some suppliers may voluntarily choose to send the updated version of the SDS to their customers immediately, without any delay or new orders. But it is important to know that suppliers usually do not send SDS immediately, just because they were updated. This means that customers might need to ask suppliers or manufacturers for updated versions from time to time.
Depending on the jurisdiction, suppliers can have different deadlines given by regulation for the SDS updates. In the US, according to Occupational Health and Safety Administration’s (OSHA) legislation, suppliers and employers need to update the SDS within three months after they become aware of any significant information about their chemical’s hazards or ways to protect against such hazards. This requirement is also connected to the preparation of labels, as the same information might apply to labels due to changes in classification and in this case, suppliers and manufacturers have to update their labels within six months.
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What are the Globally Harmonized System for Classification and Labelling of Chemicals (GHS) and national requirements for Safety Data Sheets?
Today, most countries around the world follow the Globally Harmonized System for the classification and labelling of chemicals (GHS), which is implemented in some way in their local chemical management frameworks. Among other things, GHS prescribes SDS requirements, including its content and format. At least, in theory, GHS was meant to fully harmonise chemical hazard communication – classification and labelling. Still, since the GHS is a 'non-binding' system of hazard communication, countries can choose which chapters or revisions of the GHS they want to implement. There are currently nine published GHS revisions, and countries can choose which revision they want to implement. Not only that, but the country’s authorities also have the freedom to choose which hazard classes and their categories they want to implement.
Still, most of the SDS’ you can find around the world today have been made according to the GHS rules. These rules are quite complex and can sometimes be overwhelming even for the experts, but recognising whether the SDS is made according to these rules or not isn’t always that hard.
There are a couple of tricks that can help you check whether your suppliers have provided you with the GHS compliant SDS or not.
So, the first and easiest thing that should be checked is whether it is stated somewhere in the SDS that it is made according to GHS or local legislation by which the GHS has been implemented, in the EU, for example, that are REACH and CLP regulations. Another really important thing is that the SDS has a 16-section format. We will note here that some countries like the US have adopted this format but have made certain sections non-mandatory, but still, the section headings and numbering should be there. One more important clue could be the date of preparation of the SDS. If the SDS is older than June 15 2016, for example, in the US means that the SDS might not have been prepared according to the GHS rules. This is the date by which the end-users needed to comply, while manufacturers had to comply by June 2015 and suppliers by December 2015. This means that anything prepared before those dates is likely not compliant. Additional indicators can be the pictograms used in the SDS if the SDS contains one of the 9 GHS pictograms that could indicate that the GHS rules have prepared it. But, this one is tricky because only certain hazard classes and categories need to be labelled with these pictograms. In the case of products that are not classified as hazardous, pictograms will certainly be missing.
These ‘’first glance’’ checks might help you identify SDS’ which are not made according to GHS, but it is important to note that they are by no means guarantee that the SDS is fully compliant with the local GHS requirements even if the result of the check is positive.
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Are there any fines and penalties for non-compliance?
The short and simple answer is yes. Of course, there are. Any country that has implemented GHS in their local chemical management framework has also set up the legal binding of these regulations and specified fines and penalties associated with the breach.
For example, in the US, the maximum fines that OSHA can issue, usually for serious violations regarding hazard classification, labelling, pictograms and such, is more than $10 000 per violation. Besides monetary fines, there are also penalties and punishments that can lead to a prison sentence for responsible persons. This is why it is so important always to be compliant with the latest local, national, regional and federal legislation.
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Can SDS’ be stored in digital format?
Businesses that handle chemicals should have SDS’ for each hazardous substance or chemical product they manufacture, distribute, or import. The main purpose of these documents is to provide safety information for workers at the workplace and inform users about any potential dangers of the chemicals purchased or used. This is why SDS' are important documents that should be available, at all times, to the employees who handle these products. Furthermore, they should also be provided to customers and vendors.
Depending on the company’s size or industry, it may handle a couple of hundred to thousands of chemicals every day. This makes tracking everything extremely hard, especially storing it into binders or folders and then finding the SDS you need or when it is time to update it. Luckily, regulators thought about this and are following the digitalisation trends, so the regulations around the world permit the use of electronic copies and digital ‘binders’ for the organisation of the safety data sheets. Usually, chemical management software tools are used which allow the user to store all the data online with advanced search options. This helps companies to process and organise information more efficiently and saves them money and time in the process.
Electronic access to SDSs is permitted if the employee knows how to access the SDSs and can access them at the workplace. The electronic database should be easy to use and help employers identify hazardous chemicals in the workplace. Furthermore, the SDS’ should be up to date, and the employees should be trained about the chemical hazards and how to find the right SDS.