Preparing Safety Data Sheets (SDS) – Part 5

Special cases and best practices

MSDS-Europe – Safety data sheet knowledge base – Preparing Safety Data Sheets (SDS) – Part 5: Special cases and best practices

In the previous parts of this series, we presented, step by step, how to compile a safety data sheet and what information each section of the SDS must contain.

To conclude, let’s consider a few additional factors and special cases that can arise during the preparation and use of SDSs.

We cover exposure scenarios (annexes to the SDS), keeping SDSs up to date, and typical mistakes to avoid. In addition, we offer advice on how SDSs can be used effectively to improve workplace safety, and what support can be used if you are unsure about something.

One of the simplest ways to avoid many typical mistakes is to base the SDS on reliable information sources and databases for safety data sheets, instead of copying data from unknown or outdated documents.

(Remember that the official Guidance on the compilation of safety data sheets also provides further explanation on these topics – it is available on the ECHA website.)

Exposure scenarios and extended SDSs

If a substance has certain hazardous properties and is manufactured or imported in large quantities, the REACH Regulation may require the development of an exposure scenario (ES) as part of the chemical safety assessment.

An exposure scenario is supplemental information describing how to use the substance safely throughout its life cycle (from manufacture to use to disposal). When exposure scenario(s) are required, they must be attached to the SDS as an annex; in that case, the document is referred to as an extended safety data sheet (eSDS). In practice, this means attaching the exposure scenario(s) to the SDS, and/or referencing them appropriately (e.g. in Section 16).

What does this mean for the user?

If you purchase a hazardous substance and receive an SDS of 50 pages with several annexes at the end, it likely includes exposure scenarios. These annexes contain detailed descriptions—for example, how to use the substance safely in a given industry and which risk management measures to apply so that the risk remains at an acceptable level.

Important: Downstream users must check whether their own use of the substance is covered by the exposure scenario. If it is not, they must inform the supplier or carry out their own assessment in accordance with the applicable rules. This mechanism ensures that hazardous substances are used under conditions that are safe for the relevant uses.

Exposure scenarios for mixtures: Exposure scenarios are typically developed for individual substances, whereas most end users handle mixtures (finished products). In practice, relevant information from the component substances’ exposure scenarios must be reflected in the mixture’s SDS where applicable.

For example, if a cleaning product mixture contains a solvent for which an exposure scenario exists, then the mixture SDS (in particular Sections 7 and 8, and where relevant Sections 11–12) should take into account the operational conditions and risk management measures described in that exposure scenario. This may be done by attaching relevant exposure scenarios as annexes or by providing consolidated, substance-specific information in the SDS. The key is that users receive all relevant information—whether they are using a substance or a mixture.

Maintaining and updating SDSs in practice

We have already stressed the importance of keeping SDSs up to date.

Here are some practical tips:

Tracking

Establish a system (even a digital register) to track SDS versions and revision dates for all substances and mixtures used or supplied by your company. Check regularly (for example, annually) whether a newer version is available from your suppliers, and whether any changes in your own products have occurred that would require an SDS update.

Monitoring legislation

Stay informed about changes in chemical safety legislation. For example, if new hazard classes are introduced in the CLP Regulation or occupational exposure limits are revised, SDSs should be reviewed. A major example was Commission Regulation (EU) 2020/878, which has applied since 1 January 2021 and amended Annex II to the REACH Regulation; after the transition period (ending on 31 December 2022), only SDSs compliant with Regulation (EU) 2020/878 may be placed on the market.

Integrating new information

If you become aware of new toxicological or ecotoxicological information about your product (for example, more severe long-term effects than previously assumed, or relevant experience from incidents), the SDS must be updated accordingly. This may also arise if a new use is identified—then the use information in Section 1 and the handling advice in Section 7 may need to be updated.

Communication down the supply chain

Ensure that when an SDS is updated, all affected recipients receive the new version. A common problem is that updates “get stuck” and do not reach all users. It is advisable to send the revised SDS (e.g. by email) to customers and, where appropriate, request confirmation of receipt.

If SDSs are available for download on your website, it is helpful to indicate “updated on [date]” so users can see that a new revision exists.

Common mistakes in SDS preparation – what to watch out for

Even experienced companies can have errors in their safety data sheets.

Here are some common mistakes or gaps to avoid:

Incorrect or incomplete classification

Sometimes Section 2 of the SDS does not list the hazard classification correctly, or an important hazard statement is missing. For example, a mixture might require classification for skin irritation, but the SDS does not include “Skin irritation, Category 2; H315.” This can be misleading.

Solution: Use up-to-date classification data and ensure the mixture classification is derived correctly from the hazardous ingredients (including any specific concentration limits and M-factors, where applicable).

Inconsistency between sections

A frequent mistake is that different parts of the SDS contradict each other. For instance, Section 9 might state that the product is not soluble in water, but Section 6 recommends washing spills away with water. Or Section 2 indicates the product is not flammable, but Section 5 is written as if it were flammable. Such contradictions suggest the SDS was assembled carelessly from templates.

Solution: Review the SDS thoroughly as a whole and check it for logical consistency, not only section by section.

Overly generic statements

Sometimes an SDS contains generic phrases that do not provide practical guidance. For example: “Avoid all possible exposure,” or “Use appropriate protective equipment,” without specifying what “appropriate” means. Such vague advice is not useful.

Solution: Be specific—identify the necessary protective equipment, the materials or conditions to avoid, and the concrete steps to take.

Outdated references or legislation

In some SDSs, you might still find references to old EU directives or systems that are no longer applicable, simply because the SDS has not been updated for years. For example, references to the old orange hazard symbols or classification under the former DSD/DPD system.

Solution: Regularly review SDSs and update regulatory references (especially Section 15) to reflect current legislation.

Language/translation errors

For SDSs in the local language, a common issue is literal translation or awkward phrasing that makes understanding difficult. For example, writing “Robbanás biztos berendezés” instead of the correct “Robbanásbiztos berendezés” (Hungarian for “explosion-proof equipment”). Such errors can cause confusion.

Solution: Have the SDS translated by a qualified professional and, if possible, have the final text proofread by a native-speaking expert with relevant technical knowledge.

The SDS as a workplace safety tool

A well-prepared safety data sheet is not just a document kept for inspections. Its real value lies in supporting safer day-to-day work.

Some tips on how to use SDSs effectively:

Safety training

Use SDS information to train employees. In training sessions, review the relevant SDS, show the hazard pictograms, and discuss what the hazard statements (H statements) and precautionary statements (P statements) mean.

For example, if you use solvents in a workshop, the SDS explains why adequate ventilation is needed and why ignition sources must be avoided.

Risk assessment

Workplace chemical risk assessments rely on SDS properties and recommendations.

For instance, using information from Section 8, you can determine whether local exhaust ventilation is sufficient or if workers need respiratory protection. It is good practice to keep the relevant SDSs linked to (or attached to) your risk assessment documentation.

Emergency planning

For emergency response plans (e.g. spills or fires), take into account the first-aid and fire-fighting information in the SDS.

In facilities handling hazardous substances, emergency plans may include the SDSs of key hazardous materials so responders can access them immediately.

Communication with suppliers

If something in an SDS is unclear, contact the supplier (manufacturer) for clarification using the contact details in Section 1.

For example, if you are unsure about glove material or breakthrough time, ask the supplier to clarify the recommendation.

Expert assistance and resources

When preparing and managing safety data sheets, you do not have to solve everything on your own—there are many sources of support:

Official guides

The European Chemicals Agency (ECHA) and national authorities have published guidance documents (this series is based on one such guide). For example, the “Guidance on the compilation of safety data sheets” provides explanations, examples and practical recommendations. Use such guidance if you are unsure about how to interpret a requirement.

Software and templates

Many commercial tools support SDS authoring. They may include regulatory databases and can generate text in multiple languages. While useful, they do not replace human expertise. Always review software-generated SDSs for accuracy and completeness.

Consultancy experts

If your company does not have an in-house SDS specialist, you can work with chemical safety consultancies. For example, MSDS-Europe (ToxInfo Ltd.) provides services for compiling, reviewing and translating safety data sheets, as well as submitting hazardous mixture notifications via the EU system (e.g., Poison Centre Notification (PCN) submissions).

External experts keep track of regulatory changes and can often compile SDSs more efficiently and accurately than organisations without the necessary expertise. This approach is especially helpful when working with many hazardous substances or supplying products to multiple countries (requiring SDSs in multiple languages).

Authority and industry helpdesks

The EU has a REACH-CLP Helpdesk network. You can direct questions to these helpdesks if you are unsure about a specific requirement. In addition, industry associations may provide training and support on SDS and chemical safety compliance.

This 5-part series has provided an overview of key steps and considerations for preparing safety data sheets.

We hope the information is useful for manufacturers, distributors and users alike. If there are still uncertainties in your organisation regarding SDS management, it is advisable to consult experts.

The original guidance document on which our articles were based can be accessed here: Guidance on the compilation of safety data sheets (ECHA, 2021).

Preparing a safety data sheet is not an administrative formality, but a task that requires professional competence. It is wise to work with a service provider or expert who is familiar with the REACH and CLP rules and stays up to date with changes.

Further parts:

• Part 1: Introduction and Regulatory Background
• Part 2: Responsibilities and the SDS Compilation Process
• Part 3: The first 8 sections of the SDS in detail
• Part 4: The remaining SDS sections (9–16)

Thank you for joining us in this series!

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