The content of an SDS – Responsibility
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The initial responsibility for drawing up the safety data sheet falls on the manufacturer, importer or only representative who should anticipate, so far as it is reasonably practicable, the uses to which the substance or mixture may be put.
Actors further down the supply chain should also provide a safety data sheet, drawing on, checking the adequacy of, and adding to, the information provided by their suppliers to cater for the specific needs of their customers.
Where there is a chain of supply, the requirements of REACH in relation to the provision of safety data sheets apply at each stage of the supply chain.
In all cases, suppliers of a substance or a mixture which requires a safety data sheet have the responsibility for its contents, even though they may not have prepared the safety data sheet themselves. In such cases, the information provided by their suppliers is clearly a useful and relevant source of information for them to use when compiling their own safety data sheets.
However, they will remain responsible for the accuracy of the information on the safety data sheets they provide (this also applies to SDSs distributed in languages other than the original language of compilation).
The text of the Revision of Annex II specifies in point 0.2.3 that: “[…] The safety data sheet shall be prepared by a competent person who shall take into account the specific needs and knowledge of the user audience, as far as they are known. Suppliers of substances and mixtures shall ensure that such competent persons have received appropriate training, including refresher training.”
SDS format and content are defined by Article 31 and Annex II of REACH Regulation. The latest change is from 1.6.2015 by Regulation No. 830/2015/EC and safety data sheets issued before 1.6.2015 must be in compliance till 31.5.2017 as a latest.
Classification in the safety data sheets is in compliance with CLP Regulation No. 1272/2008/ES from 1.6.2015. For the cases where mixture was classified labelled and entered the market before that date, then exemption to re-clasify is valid till 1st of June 2017.
Other reason for the SDS revision is CLP Regulation up-date (ATE) No. 918/2016/EC from 19.5.2016, were e.g. some hazard phrases are changed (H). This regulation has to be followed from 1.2.2018 as a latest.