Safety Data Sheets are currently under scrutiny due to the launch of ECHA’s fifth and sixth REACH Enforcement Projects. Both projects involve EU Member States inspectors checking the quality and accuracy of SDSs throughout the supply chain.  Failures in compliance could result in fines, penalties and even criminal prosecution.

the REF-6 Project

The Forum for Exchange of Information on Enforcement (Forum) is a network of authorities responsible for the enforcement of the REACH and CLP regulations in the EU. They coordinate the network of enforcement authorities in the different Member States by use of REACH-EN-FORCE (REF) projects. The ultimate goal of the REF-projects is to improve the quality of enforcement and increase industry compliance with chemical hazard regulations.

The Five previous REF Projects include:

REF-1 on registration,
REF-2 on supply chain duties,
REF-3 on registration (continuing REF-1 but with a different emphasis and targets),
REF-4 on restrictions,
REF-5 on extended SDSs.

The sixth coordinated enforcement project (REACH-EN-FORCE-6 (REF-6)) is presently underway and aims to focus on hazard classification and labelling of mixtures. It will also focus on the compliance of Safety Data Sheet sections relating to classification and labelling: the most relevant sections being 2, 3, 9, 11 and 12.

Field inspections are set to start at the beginning of 2018 (inspections of online sales have already begun) and a publication of the results of the report is expected around the end of 2019.

Key areas of focus

Companies can expect key areas of focus to include:

  • The quality of sections 2 and 3 of the Safety Data Sheet;
  • Compliance of the classifications with the CLP requirements;
  • Checking of mixture classifications;
  • Coherence of labels with the SDS

The inadequate quality of safety data sheets was one of the issues raised when the proposal for the REF-6 project was advanced – 17% of safety data sheets reviewed during the first enforcement project were found not to be available in the required languages or have the required headings.

Consequences & PENALTIES of Non-Compliance

In most cases, the initial reaction to non-compliance would involve corrective measures. This includes verbal or written advice on how to correct issues and administrative orders that provide a more enforceable mandate on the scope of corrections required.

However, in some cases, first inspections can result directly in sanctioning measures. These could include fines, penalties or even referral for criminal prosecution. The likelihood of sanctioning measures being imposed on companies when the softer corrective measures have not been implemented in follow-up inspections would also be much higher.

How can HIBISCUS help?

Hibiscus’ Prometheus Safety Data Sheet software has been specifically designed to author and manage SDSs.

Using our 35 years’ experience in the hazardous goods labelling industry, we’ve developed Prometheus to simplify and streamline the Safety Data Sheet process, saving you time and money.

Designed for flexibility and ease of use, Prometheus allows you to create customisable templates and layouts for individual markets and customers. Its built-in database lets you store and manage your templates so the creation process can be quickly and easily automated. Once completed Prometheus streamlines distribution of the SDS sending it directly to your customers (or directory) via email or PDF.

Prometheus can be used independently, as your ideal SDS creation and distribution solution, or integrated with our Enterprise labelling software to form an integrated solution which covers all of your labelling requirements, without the need for dual entry of data.

Prometheus takes the strain out of creating and managing Safety Data Sheets and helps you fulfill the materials SDS requirements under GHS, ADR & REACH.


For more information, or to see Prometheus in action, call us on 0113 2424272

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