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 supplying an SDS.

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 use SDS translation software often provide the sheet in the buyer’s language even when the legislation does not assign them this obligation. However, extra caution is advised with software-generated SDSs, because their professional quality is often questionable. A literal human translation is likewise not automatically satisfactory: only a small part of SDS preparation/translation is classic linguistic work; national legal requirements and the content of the SDS (e.g. classification) must always be verified.

Step two:

Next, we must check whether the SDS is up to date — this is often loosely referred to as its validity period. From a professional point of view, there is no formal “expiry date”; however, there are clear rules for updating an SDS that we should definitely know.

Further steps:

Further compliance checks depend largely on the company’s activities and on the nature of the substances/mixtures used. If we are distributors buying products from a domestic source, accepting a non-compliant SDS mainly carries the risk that our own customer will reject the product and we will lose market share.

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

Downstream users usually have the most tasks related to received SDSs. See our summary of background information for downstream users on SDS-related obligations.

Please note that downstream users already have obligations to check the content of the SDS, and the authority may review this 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 structure, and whether it meets the current content requirements of Regulation (EU) 2020/878.
What should you do if the received SDS is non-compliant with Regulation (EU) 2020/878 or contains outdated data?
The entity placing the product on the market must have the SDS updated or prepare a new SDS in order to place the product on the market lawfully in the relevant EU Member State.
Who bears legal responsibility for errors in a supplied SDS in the EU?
The supplier responsible for placing the product on the market in the given Member State (e.g. importer or distributor, depending on the supply chain role) bears the responsibility; the authorities may impose sanctions even if the faulty SDS originated from another supplier.