Before anyone asks, yes I have done a search both in forum and HSE and not found what I’m looking for. The product in question is a gel fill lead acid battery. I have been presented with a nine (9) part MSDS dated June 2009, being used to seeing sixteen (16) part MSDS’ I contacted the supplier saying there something missing from his sheet. His reply is the product is imported from Europe and his supplier is saying the nine part MSDS is correct. To further muddy the water my supplier is saying what I’m asking for is a Health & Safety data sheet the difference being between product and individual part that makes up the end product. Question time: 1. When I (or any customer / supplier) ask for a MSDS how many sections should I expect to see, regardless of individual component or finished article here in the UK and Europe respectively? 2. What legislation in UK covers MSDS’? (I believe I know the answer but just in case the goalposts have moved recently). From what date was the most recent UK and European legislation introduced? 3. Is there a Health & Safety data sheet I should have been asking for all this time instead of a MSDS? Thanks for your answers Regards, Confused Badger

Hi Barrie quick answers: 1) you should be looking at 16 sections regardless across the UK and Europe. 2) CHiP Regs or CLP Regs cover this in the UK (REACH regulations are enacting CLP in replacement of CHiP with a five year transition period ending in 2015 for mixtures). 3) The terms HSDS and MSDS have been replaced by Safety Data Sheet Sounds like both your supplier and the manufacturer have failed to act in accordance with their duties under the REACH regulations which came in to force within the UK June 2007.

Barrie - you have mail. CLP states that the responsibility for the safety data sheet lies with REACH, although much of the actual data that will be inserted is covered by CLP! During the transition period either or both sets of data (e.g. both risk phrases and hazard statements) may be shown. At least that is how I interpret what is stated in both REACH and CLP. Since there are differences between risk phrases and hazard statements (and several new pictograms) the potential for confusion seems high. There is also the subject of Exposure Scenarios (ES), to be issued by each registrant of a substance that may be a constituent of a mixture (note that preparations are now mixtures). ES must cover each use for which that substance has been registered with Helsinki. It will be illegal to use a mixture for a use that has not been registered for each substance in the mixture, so check that the ES supplied with your safety data sheet all cover your use. If you aren't yet confused I could go on... and on... and on! My own approach is for the time being to fall back on the still valid Health and Safety at Work etc. 1974 Act. Take a look at section 6-1, then insist that your supplier complies with his duties under that section. Chris

Herewith is the latest update to my earlier posting in a form of reply to the supplier: Barrie After consulting some of the major battery manufacturers and observing the MSDS for their products, it is my conclusion that VRLA batteries are not covered by Reach etc. The battery is a product and not a chemical, it is in a sealed box with no major risk to health and safety. The MSDS supplied covers the ‘ingredients’ and their various requirements in case of an emergency. Neither XYZ Company nor the manufacturers supply any other documentation. Should you wish to check out these details please type into Google ‘Exide VRLA Battery MSDS’, this can also be applied to any other manufacturer. You will only receive 9 or 10 parts to the MSDS. I hope this helps to resolve the issue ..... So it would appear the RonH was right, now to chase for the contents SDS! Badger