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Birchall31628  
#1 Posted : 07 October 2011 10:17:19(UTC)
Rank: Forum user
Birchall31628

Hi, I have been advised that we are to supply substances for example pH NEUTRAL CONTAINS NO ACIDS OR LYES CONTAINS NO NMP (N-METHYL-PYRROLIDON) CONTAINS NO PARAFFIN OR PRESERVATIVE AGENTS Do I still need safety data sheets for this, and if so in what format? I can't help but think that there may be something hazardous in there, otherwise the product would nit do it's job??
Jane Blunt  
#2 Posted : 07 October 2011 10:40:38(UTC)
Rank: Super forum user
Jane Blunt

What do you mean by 'supply' - are you selling these cubstances on, and if so, to whom (members of the public?, workplaces?)? It isn't very helpful having a list of what is not in it. I would want to know what IS in it. What is its job?
Birchall31628  
#3 Posted : 07 October 2011 10:44:52(UTC)
Rank: Forum user
Birchall31628

Hi Jane, sorry they are alledged eco friendly products such as graffitii remover, graffitti cleaner which are water based. Yes they are products that we propose to sell.
Birchall31628  
#4 Posted : 07 October 2011 10:52:05(UTC)
Rank: Forum user
Birchall31628

Also, we do have technical data sheets but they are not safety data sheets as I see it
chris.packham  
#5 Posted : 07 October 2011 14:39:09(UTC)
Rank: Super forum user
chris.packham

They may be water-based, but if they can function effectively as graffiti remover, etc., then I cannot imagine a formulation that will not contain some substances that will be capable of causing adverse effects on the skin. In any event, the safety data sheet is just one aspect of the information you need to provide. Take a look at section 6-1 of the Health and Safety at Work etc. Act 1974. You will see that you have a duty to provide information such that the product can be used safely for the purpose for which it has been supplied. This is quite a different requirement to that for the safety data sheet (which is for CHIP, not COSHH). This is a problem I commonly encounter. A substance is stated on the safety data sheet that it is non-hazardous, whereas the performance of the product indicates otherwise. Eventually, if I succeed in obtaining information on the constituent it becomes clear that, whilst the safety data sheet might well conform with CHIP, the information therein is useless for COSHH and certainly does not ensure that the supplier has conformed with his duties under the Act. Just as a final point, there are at least 8 substances considered as common sensitisers by the dermatological community (who will stock these in their clinic for patch testing) but which have never been classified as R43 and will therefore seldom feature on the safety data sheet as sensitisers (if they appear at all!). When a worker then develops an occupational contact dermatitis, who has failed in their duty? (Rhetorical question as I am not aware of a court judgement on this yet.) Chris
Birchall31628  
#6 Posted : 10 October 2011 08:21:44(UTC)
Rank: Forum user
Birchall31628

Thanks Chris!
M Colbert  
#7 Posted : 10 October 2011 16:08:22(UTC)
Rank: New forum user
M Colbert

Birchall31628 It would be advisable to verify the product(s) you intend to supply do not contain a substance or substances of very high concern (SVHC) listed under REACH. The easiest way to identify this is to check the ‘official candidates list’ on the European Chemicals Agency (EChA) website: http://echa.europa.eu/ch...didate_list_table_en.asp REACH applies to all substances (unless covered by other legislation) or mixtures so if your products do contain SVHC’s then you will have an obligation under REACH to communicate to your customer(s) (downstream user) and provide the necessary information (SDS) to enable them to manage the risks they are exposed to.
Birchall31628  
#8 Posted : 12 October 2011 09:03:36(UTC)
Rank: Forum user
Birchall31628

Thanks M Colbert.
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