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SECTION 2: Hazards identification

1272/2008 Main findings

2.1 Classification of the substance or mixture

Section of the SDS Sum of No. of Total % of sections: sections: info sections: no. SDSs info not is present but info is checked checked adequate/ not not for this with not adequate/not present section issues in present appropriate this section 2.1. Classification of 43 36 7 127 34% the substance or mixture - Substance - 21 5 16 36 58% Regulation 1272/2008 (CLP) - Mixture - 71 48 23 181 39% Regulation 1272/2008 (CLP) Main problems:  Assessments of Section 2.1 in 127 SDSs showed that: o classification was incorrectly assigned in some cases due to the fact that the information provided in Section 3.2 was not correct for example, provision of incorrect concentration ranges (percentage range too wide) or the harmonised classification of ingredient substances was not provided in section 3.2 o information was inconsistent with labelling information o hazard statements were omitted o classification was not present although required.  Additionally, information from other sections in the SDS was not taken into account resulting in incorrect classification provided in section 2.1. Examples of this are not taking the extreme pH provided in section 9 into consideration, or information from sections 11 and 12 not correlating with the classification.  Specifically, assessments of the information provided for substances (36 SDSs checked) recorded that issues related to: o harmonised classification not being used o missing hazard statements.  Assessments of the information provided for mixtures (181 SDSs checked) recorded that issues related to: o Incorrect classification (43 cases) (including conflicting information with that provided in section 3) o missing hazard statements.  Assessments also showed that information on hazard identification was in section 3 rather than in section 2 which indicates that the SDSs were not in compliance with REACH.  In seven assessments of SDSs for mixtures, classification was provided according to the revoked Dangerous Preparations Directive (DPD) only (no CLP classification was provided).

2.2 Label elements

Section of the SDS Sum of No. of Total % of sections: sections: info sections: no. SDSs info not is present but info is checked checked adequate/ not not for this with not adequate/not present section issues in present appropriate this section 31 22 9 79 39% - Substance - 8 0 18 44% Regulation 1272/2008 (CLP) 4 0 15 27%

Signal word

6 5 1 15 40% 50 30 20 183 27% 58 38 20 183 32%

Hazard statements

4 0 14 29% - Precautionary 3 2 1 12 25% If only Hazard/Risk 5 0 5 7 71% codes are given is there a reference to Section 16? Supplemental 7 0 7 9 78% information (Arts 25& 32(6) of CLP) - Mixture - 60 42 18 178 34% Regulation 1272/2008 (CLP) 54 32 22 183 30% - Precautionary 58 38 20 182 32% Supplemental 66 5 61 113 58% information (Arts 25& 32(6) of CLP) Main problems: Overall the main issues recorded related to:  missing or incorrect hazard statements or pictograms  incorrect classifications including classification for endpoints missing  the classification differing from that provided in section 2.1  the harmonised classification was not provided For substances the issues noted in section 2.2 were:  the harmonised classification was not provided and  incorrect hazard statements were provided. For mixtures, of the 183 SDSs checked, the issues noted in section 2.2 were:  inadequate classification of mixtures resulting in incorrect labelling  incorrect or missing hazard pictograms  the signal word was not provided at all or was incorrect  hazard statements were not provided or were incorrect due to the incorrect classification being assigned – in some cases due to lack of consideration of extreme pH  regarding precautionary statements non-compliances were similar to those above with statements not provided or were provided incorrectly, for example, they were not worded according to CLP or did not reflect the classification  supplemental information was not provided at all or not provided correctly, e.g. EUH statements were not provided or the name of the allergenic substance was not provided correctly for EUH208  there were cases (4) where labelling according to the revoked DPD only was provided with no CLP labelling information given.

2.3 Other hazards

Section of the SDS Sum of No. of Total % of sections: sections: info sections: no. SDSs info not is present but info is checked checked adequate/ not not for this with present section issues in not adequate/not this present appropriate section

Other hazards

58 2 56 163 36% Main problems:  Inadequate information was provided in 2 cases in section 2.3 - information on freezing properties not provided as ”other hazard” although required in two SDSs.  Information was not present, e.g. indication of whether the substance or mixture meets the criteria for persistent bio accumulative and toxic (PBT) or very persistent and very bio accumulative (vPvB). Recommendations from the WG: Based on the non-compliances noted, recommendations for improving the quality of section 2 of the SDS include: Recommendations for ECHA ASOs: 1. As it was noted that information required in section 2 was provided in section 3 and vice versa showing that there are SDSs which have not been updated in line with the latest update to Annex II of REACH (Reg. EU No. 2015/830), companies must be made aware of the need to provide updated SDSs and recipients must request SDS compiled in accordance with Annex II from their EU supplier. 2. It should be highlighted to formulators/importers of mixtures that there is a need to check consistency between sections 2 and 3 of the SDS, especially with regard to the provision of the correct concentration ranges in section 3.2. 3. Additional consistency checks are required with information in other sections of the SDS such as section 9 for information on flammability, pH, sections 11 and 12 for consistency with toxicological and eco-toxicological test results. 4. Advise companies to check if a substance or the ingredients of a mixture have harmonized classification in accordance to Article 4(3) of the CLP Regulation. 5. Advise companies to use the Guidance on the compilation of safety data sheets provided by ECHA. 6. Guidance is needed on labelling compliance. 7. Advise companies to request that non-EU suppliers provide the recipient of the substance or mixture with a safety data sheet compiled in accordance with Annex II, or information that will allow the importer to conclude whether the substance/mixture is hazardous and compile a compliant SDS when required. Recommendations for national enforcement authorities: 8. Allocate resources to guide and help companies and inform them about the importance of the correct labeling and hazard information for the workers e.g. by using checklists developed by industry or authorities 2.3.3.