Since many years safety data sheets are a well-established instrument for communication of hazard and safety information along the supply chain.

And yet the legal regulations governing the compilation of safety data sheets have been adapted and revised many times.

Actually the requirements for compilation and transmission of safety data sheets are regulated in REACH Article 31 and Annex II, further specified by ECHA Guidances. In some countries also national regulations apply as if TRGS 220 in Germany, which was revised on 2 May 2018.

A supplier has to provide a safety data sheet, if a substance or mixture is classified as dangerous, a substance is persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) or if a substance is subject to authorisation.

But there are more cases, were a supplier shall provide the recipient with a safety data sheet upon request, e. g. if the mixture does not meet the criteria for classification as dangerous but contains certain dangerous substances at low level or if the mixture contains substances with community workplace exposure limits.

The safety data sheet must be made available free of charge in paper or electronic form no later than the date upon which the substance or mixture is first supplied.

Also if there is no duty to compile a safety data sheet, according to REACH Article 32 suppliers need to forward information on REACH registration status as well as risk management measures along the supply chain.

Suppliers must update their safety data sheets immediately if new information on risk management measures or hazards become available. Very often it creates high administrative burden for downstream users to forward the information generated as part of REACH registrations down the supply chain.

A relatively new element of hazard communication is the so called extended safety data sheet. It contains exposure scenarios, which itself are part of the of chemical safety report of the REACH registration. Downstream users are facing the challenge to check the exposure scenarios and to compare the described operational conditions and risk management measures with their own conditions of use. Furthermore information given in the exposure scenarios also need to communicated along the supply chain.

We are happy to assist you in the preparation or administration of your safety data sheets and in the implementation of the resulting measures. Please contact us, we will work out a tailor-made package for you.