What we definitely have to check in safety data sheets

MSDS-Europe – What we definitely have to check in safety data sheets

Before we list the main points for checking a received Safety Data Sheet, please read our article about the rules for making an SDS available.

Step one:

First we can (and must) check the language of the supplied SDS. It may sound odd, but the supplier of a chemical product is not always obliged to provide the SDS in our own language.

Companies that have SDS‑translation software often like to give the sheet in the buyer’s language even when legislation does not assign them this task. However, extra caution is advised with software‑generated SDSs, because they are usually professionally questionable. A literal human translation is likewise not automatically satisfactory: only a small part of SDS preparation/translation work is classic linguistic work; national legislation and the sheet’s contents (e.g. classification) must always be verified.

Step two:

Next we must check whether the sheet is “up‑to‑date”—often loosely called its validity period. From a professional standpoint there is no formal “expiry date”, yet there are rules on updating an SDS that we should certainly know.

Further steps:

Further compliance checks depend largely on the company’s activities and on the nature of the substances/mixtures used. As a distributor buying products from a domestic source, taking over a non‑conforming SDS only risks that our own customer will reject the product and we lose market share.

If we buy a chemical in another EEA country, our company becomes liable for PCN notification and labelling, which we cannot carry out properly if we rely on an incorrect SDS.

Downstream users probably have the most tasks with received SDSs. See our summary of background information for downstream users on SDS obligations.

Note that downstream users already have content‑checking duties regarding the SDS, which the authority may audit during on‑site inspections. Special measures are required if the SDS contains an exposure scenario.

 

Service recommendation:

 

Useful articles:

 

Quick questions and answers

What are the first three items to check on an SDS received from a foreign supplier?
The document language, the 16‑section format, and whether it meets the new content requirements of Regulation (EU) 2020/878.
What should you do if the imported SDS is non‑compliant with 2020/878 or contains outdated data?
The entity placing the product on the market must have it updated or prepare a completely new SDS to sell legally in the state member of EU.
Who bears legal responsibility for errors in a transferred SDS in EU?
The EU importer/distributor; the authorities can sanction them even if the faulty SDS came from an overseas supplier.