What is an MSDS?
The safety data sheet is a document containing 16 sections : 16 sections that provides
- Details of the health risks associated with exposure or use of dangerous products.
- The MSDS contains all the information on the handling, use or storage products.
- The MSDS must be provided in the language of the country where the product will be used.
EcoMundo gives you details of the process to comply with REACH obligations related to SDS step by step.
A safety data sheet shall be provided free of charge on paper or electronically at the latest on the date on which the substance or mixture is supplied for the first time.REACH regulation, article 31
As a supplier (formulators, manufacturers, importers)
- If substances classified as hazardous according to the CLP regulation or mixtures eligible to the hazardous mixtures classification according to the 30%/CE directive are included in the chemical product that you supply.
- When using PBT or vPvB1 substances (Annex XII).
- When using substances included on the candidate list of substances for authorization (REACH, article 59 §1).
The supplier must perform these steps spontaneously. However, the recipient may require SDS when the preparation does not meet the criteria for classification as dangerous (Articles 5,6,7 Directive 1999/45/EC), but does contain certain substances in higher concentrations.
Finally, the safety data sheet should be updated without delay by the supplier:
- As soon as new information which may affect the risk management measures, or new information on hazards are available.
- Once approval has been granted or refused.
- Once a restriction has been imposed.
As an actor in the supply chain (downstream users, distributor)
Articles 14 or 37 , require actors to carry out an assessment of chemical safety of the substance. During the evaluation, you must also ensure that the information contained in the safety data sheet are correct with the evaluation..
On request, the supplier can:
- Provide SDS for dangerous substances or preparations intended for sale to the public.
- If the information on the product allows users to take all safety, environmental and health measures, you do not have to make the request.
The actors in the supply chain concerned with articles 14 or 37 must:
- Attach a safety data sheet enclosed the scenarios of exposures (annexe XI, section 3.) .
The downstream user or distributor who makes a safety data sheet for specific uses shall:
- Using MSDS initially provided as well as scenarios of exposures (article 37, paragraph 2).
How to do?
Writing and translation of MSDS :
Writing MSDS is a complex operation that requires expert knowledge. Moreover, you will generally have to translate for each country of provision of products. To help you in these procedures, there are various software on the market that simplify your task and you can avoid forgetting a mandatory mention.
Dissemination of MSDS :
Drafting a safety data sheet is highly regulated. The latter includes 16 mandatory sections.
1. Identification of the substance/mixture and of the company.
Information to be supplemented : In the case of a substance you must indicate the chemical name as well as the identification number (n° EC, n° CAS or n° INDEX ...) or REACH registration number. In the case of a mixture you must mention the name or trade name. In section 1.2 you must mention the identified uses relevant to the substance or mixture and uses in section 1.3 you must decline the identity of the manufacturer / importer / only representative or distributor, joining it complete contact information and the phone number and email address. At last, in section 1.4 you must enter the emergency phone numbers.
This means you must : Verify that the information is in accordance with the labelling and the registration number is complete (ask your provider). In the case of registered substances, see if an exposure scenario is in annex and come into compliance within 12 months (operational and risk management mentioned).
In section 1.2 you should verify that your use is included in the field of use and in the particular case (mismatched exposure scenario, intermediates substances under strictly controlled conditions) contact your supplier. At last, for sections 1.3 and 1.4 you must ensure that the information is present, according to the labelling and that emergency phone numbers are update.
2. Hazard identification
Information to be supplemented: In section 2.1 classification of the substance or mixture should be defined according to the CLP regulation and in accordance with Directive 67/548 / EEC (substance); Directive 1999/45/EC and CLP (mixtures). Section 2.2 relates to labeling elements and the appearance of these elements is essential for the effective compliance of your MSDS.
This means you must: Use the information to assess the risks and develop internal documentation putting at disposition to users (employees). In the case of a hazardous substance, it should be mentioned: CLP pictograms, signal words (danger, caution), hazard statements (phrase H) precautionary statements (phrase P). In the case of a mixture, you must mention all the elements for the substance (see above) as well as: hazard symbols, indications of danger, the risk phrases (R phrase) CMR effects, the category of danger, the safety advice (S phrase), additional information if needed.
CAUTION: CLP classification is evolving! Read our article for more information.
3. Composition and information on ingredients
Information to be supplemented:In section 3.1 on substances you must indicate the chemical name of the main component of the substance and its other constituents and finally the identification information (EC No, CAS ...). Mixtures appear in section 3.2 and must be mentioned information on dangerous components of the mixture.
This means you must :Give the required information. For mixtures you must specify the identification number, the REACH registration number if necessary, concentration or concentration range in the mixture and the CLP classification. If a substance is considered SVHC (Substances of Very High Concern), you must notify your customers and follow the required process .
4. First aid measures
Information to be supplemented:You must specify the measures to be followed in case of inhalation, skin contact, eye screening, intake etc., and whether the medical intervention is desirable or essential.
This means you must: Clarify first aid measures and actions to avoid, especially for non-specifically trained people
5. Fire-fighting measures
Information to be supplemented: You must specify the extinguishing of the fire specifying the procedures and the dangers improper means.
This means you must: State the class of fire extinguishers.
6. Accidental release measures
Information to be supplemented: You must inform on cleaning methods and precautions.
This means you must: List all the personal and environmental precautions and describe the process of cleaning and precautions for cleaning.
7. Handling and storage
Information to be supplemented: In sections 7.1 to 7.3 complete the technical measures of prevention (health protection, safety management, environmental protection) based on product features and exhibitions.
This means you must: Be sure to put in place the organizational measures and appropriate prevention techniques, depending on the product hazards and potential exposures. Make sure that the company's work and organizational procedures are compatible with those measures. In case of joined exhibition scenarios with the MSDS make sure they are not contradictory with the actions you take. If in doubt contact your supplier..
8. Exposure controls/personal protection
Information to be supplemented:Section 8.1 relates to control parameters, and you must mention occupational exposure limits (OEL), derived no-effect levels (DNEL) derived doses with minimum effect and no predictable effect concentrations (PNEC) indicated if they exist. Section 8.2 contains all measures on collective protection, individual and environment as well as technical measures of exposure for humans and the environment.
This means you must: Ensure that the use of the substance or mixture does not entail any risk to the worker and that concentrations in the workplace are indicated below OEL. If preventive measures are not present, nor scenarios of exposures, or are conflicting with your use you should contact your supplier. It is important to ensure that the collective prevention measures and personal protective equipment meets or exceeds the instructions contained in the MSDS..
9. Physical and chemical properties
Information to be supplemented: You must specify the physical and / or additional chemical properties. (Chapter 4.9)
10. Stability and reactivity
Information to be supplemented:You need to specify the conditions and materials to avoid and hazardous decomposition products.
11. Toxicological information
Information to be supplemented:You must list the toxicological data of the product.
This means you must: Indicate the harmful health effects according to the different routes of exposure (inhalation, ingestion, projection ...)
12. Ecological information
Information to be supplemented: You must specify the ecotoxicity of the product as well as mobility, persistence and degradability of the product..
This means you must:List the harmful effects and identify every feature mentioned above
13. Disposal considerations
Information to be supplemented: You must determine the methods for safe disposal of the product or contaminated packaging.
This means you must: Explain the desirable process of removing toxic and / or contaminated substances.
14. Transport information
Information to be supplemented: You must specify the UN number, class, marine pollutant, shipping name etc.
This means you must: Specify the above statements in detail.
15. Regulatory information
Information to be supplemented:This section should (if context) contain the European and national regulations. You must specify the schedule of occupational diseases, reinforced medical surveillance etc. for products placed on the market in France. Furthermore, if the assessment of chemical safety has been made, this should be stated in this section (15.2).
This means you must: Check if the substance or mixture is subject to specific provisions and comply with regulations. If there is a chemical safety assessment you should look for an exposure scenario.
16. Other information
Information to be supplemented: In this section you should mention the information about any changes from previous versions and the CLP classification for mixtures classified according to Directive 1999/45/EC. If this is not mentioned in the previous sections you have to define the abbreviations and acronyms. Finally you can add the list of exposure scenarios that you’ll join in the annex and providing advice for the protection of human health and the environment.
This means you must: Verify all changes relative to previous versions of your MSDS.
Do not hesitate to contact our expert Fangcun Zhou by phone on +33 (0)1 83 64 20 54 for Europe and for North America please dial + 1 (778) 231-1607 or send an email at [email protected].
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