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A Safety data sheet (SDS) is considered a “living” document in which the intrinsic hazard information, risk management measures, and regulatory requirements could be varied over the time. The SDS document needs to be updated frequently to:
Based upon newly developed scientific data and evaluations from competent authorities, countries often revise their legislations on hazard classification and labelling criteria, SDS format and content, occupational exposure limit (OEL) values, or special control rules and measures etc., for certain chemicals.
Therefore, manufacturers, importers, or relevant actors in the supply chain should check and update their SDS to guarantee that the latest SDS version well aligns with the current legislation of the destination markets. This compliance would help to smooth the movement of the chemicals into and inside the country.
In the EU, for example, the list of harmonized classification and labelling of hazardous substances is normally updated on a yearly basis by the European Commission following opinions from the Committee for Risk Assessment.
Likewise, the candidate list of substances of very high concern (SVHC) for authorisation is also regularly revised based on the proposal of the Member States or the European Chemicals Agency, with the purpose of gradually replacing highly concerned chemicals the less hazardous substances or technologies when it is plausible.
SDSs of substances that fall into those lists should, therefore, be updated accordingly.
Under certain regulations, SDS revision is a legal obligation. For instance, Article 31 (9) of REACH lists specific occasions where SDS is required to be updated and reissued. Furthermore, it is compulsory to provide the updated SDS to every recipient in the supply chain to whom the substance or mixture has been supplied within the preceding 12 months.
Conditions in which suppliers are obligated to update SDS in accordance with Article 31 (9) of REACH:
(a) as soon as new information which may affect the risk management measures, or new information on hazards becomes available;
(b) once authorisation has been granted or refused;
(c) once a restriction has been imposed.
With years of experience and a commitment to accuracy, we’ll ensure your SDSs meet all regulatory requirements.
At Chementors, safety data sheet creation and updating is our daily task. We have the knowledge and experience in SDS legislation systems around the world which enables our team to keep up with revisions in SDS requirements and hazard classification of substances or mixtures.
We take care of regulatory updates which are particularly relevant to clients to inform and act on in a timely manner. At each stage of the process, we keep checking and evaluating the details and wholeness of the SDS to ensure the comprehensiveness and compliance of the ready-to-go document. In addition, our SDS authoring software – Chemeter – regularly and automatically updates the hazard classification of substances, OEL values, toxicological data, and SDS format and content requirements of different countries. Its functions also enable us to revise changes in product formulation and input new data on physicochemical properties in a fast and easy way.
Chementors hopes to give a hand to facilitate the smooth trading activities of products into and inside the country/region of interest by avoiding penalties due to non-compliance. By keeping SDS in updated mode, clients would also be assured that their target audiences are always provided with proper information on chemical hazards and risk management.
There is no fixed list of information or document that should be provided to have the SDS updated. Generally, it is very helpful to gather all available data, when possible, to make sure that the document is not only legally binding but also that all critical content is covered in the SDS.
When it is possible and available, it would be useful for us to get the following information:
In cases where SDS updating is legally compulsory, the SDS must be updated without undue delay once it meets the criteria specified by the regulation. For substances that are subjected to EU-REACH, it is important to check if they fall into the scope of Article 31(9) of REACH about SDS updating obligation. For example, when a substance is included in the candidate list of SVHC, the current safety data sheet shall be updated in section 15 to show the identification of the substance as an SVHC.
For other cases, it would be a good practice to update SDS regularly, for example, every year or every two years. This step would make sure that the current version is fully compliant with local regulations, as countries and territories frequently issue revisions to their regulations.
Furthermore, it is also welcome to voluntarily update the safety data sheet when there is any new, additional, or revised information, which you think would be significant for target audiences during the handling, transport, and use of chemicals.