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WatsonD  
#1 Posted : 07 February 2019 14:13:40(UTC)
Rank: Super forum user
WatsonD

We are using a product which is manufactured in the USA on our site installations. THe company provide us with a GHS safety data sheet, from which I have prepared a COSHH assessment.

This has never been an issue until today. The PC on site have taken the product and read the label, which lists another item not taken into account on the COSHH assessment. Now the SDS we receive is compliant with the EU directive on RoHS, but the label is the original american version. Given there are different standards and requirements in these countries, I would like to go back to the PC with a where the product is manufactured outside the EU "shouldn't read the label, read the SDS sheet" type answer, but I cannot find anything to back this up. Any constructive advice welcome please.

Roundtuit  
#2 Posted : 07 February 2019 15:42:34(UTC)
Rank: Super forum user
Roundtuit

Unfortunately you have to go back to the supplier/importer as the labelling must comply with EC 1272/2008 to be on the UK market.

A "GHS" Safety Data Sheet is not suitable as the rules in application vary by nation state - classification as listed in Section 2 must be in accordance with EC 1272/2008. The document should also be completed according to EU 2015/830 (EU 453/2010 was withdrawn effective 1st June 2017).

By example environmental hazards may not be communicated as US GHS legislation is run by OSHA to the exclusion of their EPA, we have a set size for pictograms the US does not and europe has its own local EUH hazard statements e.g. May produce an allergic reaction.

RoHS is a directive covering restriction of substances in electrical and electronic equipment - it has nothing to do with the classification and labelling of substances and mixtures

thanks 2 users thanked Roundtuit for this useful post.
WatsonD on 07/02/2019(UTC), SNS on 07/02/2019(UTC)
Kate  
#3 Posted : 10 February 2019 17:16:59(UTC)
Rank: Super forum user
Kate

I think you may mean REACH not RoHS?

Roundtuit  
#4 Posted : 10 February 2019 20:56:45(UTC)
Rank: Super forum user
Roundtuit

Nope many MSDS were annotated for ROHS compliance as suppliers struggled to get to grips with how to attest conformity to this new directive - nowadays those requiring compliance ask for a distincr declaration.

Bit like when COSHH appeared and the non enlightened ask suppliers for a COSHH sheet (actually meaning they wanted an MSDS for a COSHH assessment) - unfortunately many still believe an SDS is their employers assessment.
thanks 1 user thanked Roundtuit for this useful post.
WatsonD on 11/02/2019(UTC)
chris.packham  
#5 Posted : 11 February 2019 10:22:44(UTC)
Rank: Super forum user
chris.packham

Who is the importer and have they complied with the requirements of REACH? If so then it will be their responsibility to ensure that safety data sheet and labelling comply with current EU legislation. If not, should you even be using it?

Chris

thanks 1 user thanked chris.packham for this useful post.
A Kurdziel on 11/02/2019(UTC)
WatsonD  
#6 Posted : 11 February 2019 12:15:15(UTC)
Rank: Super forum user
WatsonD

Originally Posted by: chris.packham Go to Quoted Post

Who is the importer and have they complied with the requirements of REACH? If so then it will be their responsibility to ensure that safety data sheet and labelling comply with current EU legislation. If not, should you even be using it?

Chris

Thanks Chris but I didn't say that the SDS doesn't comply with EU regulation - on the contrary I specifically stated that it did.

My question was as to whether regulation required the importer to change the labelling on the product itself, to not only include EU compliant information and labelling but more specifically ensure they remove irrelevant information which complies to American standards. As my concern is whether this would cause confusion.

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