Rank: New forum user 
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Can anyone please explain the relevance of Risk Phrases/Hazard Statements in SDS Section 2 (& Section 16) as opposed to Section 15? Sections 2/16 have all the Risk Phrases whereas Section 15 has only some under the title Regulatory Information. In what circumstances are sections 2 & 16 to be used and what circumstances is section 15 to be used?
An explanation would be appreciated, thanks.
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Rank: Super forum user 
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Completing an MSDS is subject to guidance available elsewhere but, as someone who looks at these daily, I have noticed that authors will choose to put the information into various sections. A R or S phrase has the same 'value' where ever it is on the form. Note also that you need to consider how you are using this substance when you do your assessment for use. For example a block of steel will have a quite different impact (no pun intended) to the same amount of steel as an airborn nano powder.
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Rank: Super forum user 
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The risk phrases in sections 2 and 16 are all the phrases that apply to any of the ingredients, and the ones in section 15 are the ones that apply to the whole preparation.
If an ingredient is present at a low concentration, its risk phrase may not be carried through to the final classification.
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Rank: New forum user
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Thanks for the explanation. However, if authors put R&S phrases into different areas, i.e. sections 2, 15 & 16, then why then do we have these different sections? It doesn't seem very logical or efficient to me and it would make more sense to place them all in one section to avoid ambiguity. Why would an author leave some risk phrases out of section 15 when they appear elsewhere? Section 15 is entitled Regulatory Information and the unsuspecting user could understandably use this information only which can lead to confusion. If the authors don't know how to write an SDS properly what hope do the rest of us have at understanding them.
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Rank: New forum user
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Thanks Kate, I posted my last comment before reading your reply. Your explanation sounds reasonable - is there an official document that you may be aware of that explains this definitively for backup. The reason form my question is that I am doing a COMAH/SEVESO calculation to see if the Regulations apply to a facility. If I use the risk phrases in sections 2 & 16, then the Regulations could apply to the environmental calculation if stocks are permitted to go over a certain level. If I use the risk phrases in section 15 only, then the Regulations will not apply. Can anyone give clarification on this and/or direct me to an official document to support the approach being taken?
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Rank: Super forum user
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Murchadh
When we use the MSDS for concrete products, then the risk phrases are for the ingredients and the final product, ie cement dust, R36,37,38. But when Hydrated R41,43 when cured no risk phrases.
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Rank: Super forum user
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Sorry that I don't have a reference for this, but if you study the exact wording in sections 2 and 16 you should see that the risk phrases in section 2 are assigned to individual ingredients, and that section 16 has a heading "full text of risk phrases" indicating that it is just expanding on the risk phrase numbers used elsewhere in the msds (sometimes in section 2 you just get R36/37/38 or whatever without the text), while section 15 doesn't list the individual ingredients and so is about the whole preparation (or mixture as I think the correct term is now).
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Rank: New forum user
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