Safety data sheets are one of the main means by which handlers and users of dangerous substances are made aware of the potential hazards to their health and the environment.
Despite being a staple of the chemical industry, a few misconceptions persist about the understanding of Safety Data Sheets and their management.
Here’s 5 misconceptions which you may frequently hear…
#1 We didn’t prepare the SDS, so we’re not responsible for it
WRONG – The ECHA ‘Guidance On The Compilation Of Safety Data Sheets’ states:
“In all cases, suppliers of a substance or a mixture which requires a safety data sheet have the responsibility for its contents, even though they may not have prepared the safety data sheet themselves.”
You may be thinking that you’re not a supplier, but let’s look at the definition before we jump to any conclusions: A supplier is, everyone involved in the supply chain. Thus, your supplier has responsibility towards you, and you are primarily responsible to those to whom you have sold a chemical substance or mixture.
This means that the supplier is responsible, even if they did not prepare, or compile, the safety data sheet.
#2 Every chemical must have an accompanying safety data sheet
WRONG – It sounds like this should be accurate, but it isn’t.
- Exempt: Consumer Products.
- Exempt: Cosmetics.
- Exempt: Drugs and Pharmaceuticals.
- Exempt: Hazardous Wastes and Remediation.
- Exempt: Tobacco and tobacco product.
- Exempt: Nuisance Particulates and Dusts.
In general, a safety data sheet is required for all potentially hazardous chemicals present in the workplace, but the answer more accurately lies in how the employees use such products.
When the employer can adequately demonstrate that certain products which meet the definition of a ‘consumer product’ are being used the same way that a consumer would use them, then they would fall under the consumer products exemption.
For example: If an employer buys a couple of bottles of bathroom cleaner and then uses it to clean their own bathrooms, they don’t need to have a safety data sheet for it because the exposure to the chemicals in the bathroom cleaner are the same as what a typical consumer would experience. However, if that same employer buys the bathroom cleaner in bulk and then uses it to clean bathrooms for 8 hours a day, or uses it for some other use, such as cleaning equipment parts, then the exposure to the chemicals in the bathroom cleaner are no longer ‘typical’ and it becomes a hazard that requires a safety data sheet.
Essentially, if the employees use consumer chemical products in the same manner that any other consumer would, and as directed by the manufacturer, you probably don’t need to worry about having an SDS. However, if the employees use consumer chemical products for purposes that extend beyond that of an average consumer, especially in regards to the frequency and quantity of use, then their exposure rate is higher and you most likely do need to supply SDSs for those products.
#3 Every SDS must be kept on file for at least 30 years
WRONG – If you’re an employer faced with the prospect of having to store every SDS for a period of 30 years and you’re wondering how on earth you’re going to do that, you can rest easy because you don’t typically have to.
You are only required to keep some record of the identity of the substances or agents to which employees are exposed to for 30 years. To that end, an SDS is an acceptable record – and may be your easiest recourse, but if you choose not to retain the actual SDS, then you must retain a record of the identity (chemical name if known) of the substance or agent, and information regarding where and when it was used.
#4 Information contained in the SDS is confidential
WRONG – None of the information contained in safety data sheets is confidential.
The ECHA ‘Guidance On The Compilation Of Safety Data Sheets’ states: The information that is required to appear in an SDS cannot be claimed as confidential.
Essentially all hazardous substances must be declared in the safety data sheet if their concentrations exceed certain cut-off value (usually, 0.1% or 1% depending on hazards). Usually non-hazardous constituents do not need to be disclosed unless there are workplace exposure limits, or if they belong to Persistent, Bioaccumulative and Toxic (PBT)substances.
However, in some instances it is possible for companies to withhold information from a safety data sheet that identifies product recipes, or other proprietary details which, if revealed to others, could be detrimental to their business interests.
Companies who are concerned about disclosing the full composition of a mixture in safety data sheets, or on product labels, can request the use of an alternative chemical name for a hazardous substance to protect their trade secrets. However, there are many requirements for using an alternative name and adequate information must be provided on the nature of the ingredient for handlers to take suitable health and safety precautions.
#5 The SDS and the product label don’t have to match
WRONG – The content on the product label must always correspond to information on Safety Data Sheet.
As well as marketing material, the label must also include the necessary legal information warning customers of potential dangers such as product identifiers, hazard statements and pictograms. For this you need to follow the information on the safety data sheet of the product.
Here are few common chemical labelling errors:
- Using different identifying names on the label and the safety data sheet for the same product.
- Using black and white GHS hazard pictograms instead of red ones.
- Using a font size that is too small to read.
- Shrinking the size of GHS hazard pictograms to gain additional space for marketing text.
- Horizontally oriented text on a vertically positioned product.
- Parts of the label design obscuring the warning information.
How Can Hibiscus Help?
Safety data sheet compliance with prometheus
If you’re in the process of re-evaluating how you currently create and manage your Safety Data Sheets or chemical labels, contact us for details about our specially developed products.
Created as a joint development with Lexeus Ltd, Prometheus is our Safety Data Sheet creation and management software – a simple, intuitive and flexible solution for Safety Data Sheet compliance.
Prometheus can:
- Help your company fulfil the “materials safety data sheet” requirement
- Provide you with convenient flexibility for authoring and distributing your own SDSs
- Give you many options to produce data sheets in a variety of formats to satisfy all users
- Give you the choice to customise your SDSs by language, to suit destination, and using different graphics/images
- Save you time and effort
- Let you set different access levels to your SDSs for different users
Prometheus can be used independently as your ideal SDS creation, storage and distribution platform or combined with our companion products to form an integrated solution for all your hazardous chemical documentation and labelling requirements.