Under REACH, Safety Data Sheets must be provided, free of charge, upon first delivery. Also when an SDS is updated it must be sent to all who have received the substance or mixture over the last twelve months.
Safety Data Sheets need not be provided to the general public if there is otherwise enough information available for safe use.
The SDS must be in an official language of the Member State where the substance or mixture is placed on the market. With over twenty different languages in the EU, this may pose a logistical problem.
Automatic translation of Safety Data Sheets is however possible when only standard phrases are used.
Safety data Sheets may be distributed in digital form.
It is possible to place the Safety data Sheets on a web site for customers to download. There must however be a system that ensures and documents that the customers actually have received the documents.
An ‘Extended’ Safety Data Sheet is an SDS to which REACH Exposure Scenario’s are attached.
For dangerous substances ‘Extended Safety Data Sheets’ are obligatory under REACH, as soon as a substance has been registered.
For dangerous mixtures there are two different ways of compiling and Extended Safety Data Sheet under REACH:
• Either attach a specific Exposure Scenario for the mixture to the SDS.
• Or attach the Exposure Scenario’s for the dangerous ingredients in the mixture.
Specific Exposure Scenarios for dangerous mixtures can be compiled by using the information in the Exposure Scenario’s for the ingredients.
The first option is cumbersome, and only possible if Exposure Scenario’s for all the ingredients are available.
The second option is used in practice.
This second option is however not allowed if a separate Chemical Safety Assessment has been made for the mixture.
Making such a separate Chemical safety Assessment may be useful to prove that a mixture is not dangerous. For instance if a hazardous substance is included within the matrix of the mixture in such a way that exposure to the hazardous substance becomes impossible. This can for example be the case with alloys.
The system in Europe for classification and labelling of dangerous substances and mixtures is in the process of being replaced.
The Globally Harmonised System will take its place. The symbols and Risk Phrases are different. In some cases the criteria differ slightly: a substance can for example be ‘Eye irritant’ under GHS and not under the old EU system.
In the transition period, Safety data Sheets for substances must give the classification under both systems, and Safety Data Sheets for mixtures may contain either system.
The REACH registration number of a substance must feature on its Safety data Sheet.
The REACH registration number identifies both the substance and the registrant. The registrant is identified in the last four digits of the Registration number.
On Safety Data Sheets for mixtures, the REACH registration numbers of the dangerous ingredients must be listed. In this case however, the last four digits of the number (identifying the substance manufacturer) may be omitted.
The producer, importer or Only Representative of the mixture must be able to provide the full registration number of the substances to the authorities.
Under REACH, non-dangerous substances and mixtures do not require an SDS. There is however a need to provide information such as the registration number, the presence of Candidate List substances, details of restrictions etc.
In general, SDS-lookalike documents are produced for this purpose.
These documents need not necessarily be distributed in all EU languages. But of course they should be understandable to the recipient of the chemicals.