Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
stevestarbuck  
#1 Posted : 08 June 2010 11:11:53(UTC)
Rank: Guest
Guest

We purchase hazardous substances from within the EU, and re-brand them for sale as our products. I administer the Safety Data Sheets and effectively just re-brand the supplier's SDS adding our contact details and logo. Under REACH annex II, and in fact before, there is a requirement to identify the person responsible for placing the substance on the market including and email and telephone number. This person must be "competent". I am not competent to answer detailed chemical questions beyound what is on the SDS. Marketing would be unhappy to leave reference to our supplier on the SDS. Do we have a straight choice - employ a chemist or leave the supplier's SDS as it is with our product name added? Any ideas?
leadbelly  
#2 Posted : 08 June 2010 11:15:58(UTC)
Rank: Super forum user
leadbelly

Steve You could try asking someone at the Chemical Hazard Communication Society: http://www.chcs.org.uk/ LB
Ron Hunter  
#3 Posted : 08 June 2010 13:17:14(UTC)
Rank: Super forum user
Ron Hunter

I don't think you can legally usurp the role of the person placing the product on the market.
jay  
#4 Posted : 08 June 2010 13:43:40(UTC)
Rank: Super forum user
jay

Refer to comprehensive CLP guidance at:- http://guidance.echa.eur.../clp_introductory_en.pdf The complete suite of CLP guidance is at:- http://echa.europa.eu/clp/clp_help_en.asp Since this is a "complex" matter, my advice is for you to consult a competent person who can interpret your specific circumstances in context of both REACH and CLP. The Chemical Industries Association runs a REACH Ready consultancy and has diffrent levels of membership
Users browsing this topic
Guest
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.