Rank: Forum user
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Hoping someone can clarify something for me as I'm having one of those days where everything and its auntie is confusing me. Under what piece of legislation should a compliant safety data sheet be written by the manufacturer - REACH, CHIP, CLP other?
Also under what piece of legislation should a supplier be supplying a safety data sheet to the end user.
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Rank: Super forum user
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Rank: Forum user
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Thanks for that. Am I right in thinking that if someone imports a product manufactured in America then the person who does the importing is the person responsible for creating a REACH compliant SDS?
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Rank: Super forum user
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Not only are they responsible for producing the safety data sheet but as the importer they are responsible for all aspects of REACH compliance. If you are in this position then perhaps you should seek advice from a Dangerous Goods Advisor who can explain what this entails.
Chris
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Rank: Super forum user
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Rank: Super forum user
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Unfortunately this is still the transition period.
For mixtures the Dangerous Products Directive (CHiP in the UK) is still applicable until 31st May 2015 for manufacture - classification to 67/548/EEC or 1999/45/EC.
For substances (pure chemicals) the Dangerous Substances Directive has already been replaced by REACH EC/1907/2006 and its subordinate the Classification, Labelling and Packaging Regulations EC/1272/2008.
The US are adopting the Globally Harmonised System (HazCom 2012) in the same time frame as the EU on mixtures BUT their SDS do have classification differences thanks to the version of the UN Purple Book they have chosen to work with. So a harmonised system isn't.
SDS are only the tip of the administrative ice-berg - registration, Prior Informed Consent (for hazardous materials). Global suppliers have this covered through their compliance teams, smaller players usually sign up with an Only Representative (some one based in the EU who does the administration on behalf of the manufacturer or supplier).
http://echa.europa.eu/we...each/understanding-reach
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Rank: Super forum user
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Unfortunately this is still the transition period.
For mixtures the Dangerous Products Directive (CHiP in the UK) is still applicable until 31st May 2015 for manufacture - classification to 67/548/EEC or 1999/45/EC.
For substances (pure chemicals) the Dangerous Substances Directive has already been replaced by REACH EC/1907/2006 and its subordinate the Classification, Labelling and Packaging Regulations EC/1272/2008.
The US are adopting the Globally Harmonised System (HazCom 2012) in the same time frame as the EU on mixtures BUT their SDS do have classification differences thanks to the version of the UN Purple Book they have chosen to work with. So a harmonised system isn't.
SDS are only the tip of the administrative ice-berg - registration, Prior Informed Consent (for hazardous materials). Global suppliers have this covered through their compliance teams, smaller players usually sign up with an Only Representative (some one based in the EU who does the administration on behalf of the manufacturer or supplier).
http://echa.europa.eu/we...each/understanding-reach
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Rank: Super forum user
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GHS has been agreed & designed is to provide Harmonisation (and not identical standardisation). It makes it possible for countries & regions to take the "building blocks" such that it does not dilute their existing systems.
Yes, there will be some diffrences, but the fundamentals remain "harmonised" . Countries/regions are free to determine which of the building blocks will be applied in different parts of their systems.
Howeve where a system covers something that is in the GHS, and implements the GHS, that coverage should be consistent. For example, if a system covers the carcinogenicity of a chemical, it should follow the harmonized classification scheme and the harmonized label elements as per clause 1.1.3.1.5.4.
The GHS classification and communication requirements can be thought of as a collection of building blocks. In regulatory schemes, coverage and communication of hazards vary by the needs of target audiences/sectors (countries/regional trading blocks such as EU). Accordingly, the GHS was designed to contain the hazard endpoints and communication tools necessary for application to known regulatory schemes. The GHS is structured so that the appropriate elements for classification and communication, which address the target audiences, can be selected.
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Rank: Super forum user
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You should also ensure any new SDS incorporate Usage Sernarios to enable the user to produce a REACH Assessment as well as a COSHH Assessment
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Rank: Forum user
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I suggest you also look at ISO 11014-1 "International standards and guides for the compilation of MSDS" for information required to formulate a Safety Data Sheet.
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Rank: Super forum user
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Take a look at:
http://www.reachonline.e.../REACH_EN/article31.html
I also have a document fro the UK REACH Competent Authority - Information Leaflet Number 13 - Safety Data Sheets September 2010 which covers this topic (Opening statement says: "This leaflet explains the requirements for safety data sheets and how they will change in the future.) You can download this from www.hse.gov.uk/reach
Chris
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