Rank: Forum user
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I am currently looking at the risk/CoSHH assessment for some welding processes which use welding rods. I have requested the MSDS for the products in question from our supplier but what they have sent me does not come in the format I understand is required from HSE's L130 Chemicals (Hazards Information and Packaging for Supply) Regulations 2002. From the information provided, it looks like the MSDS they have sent me is in relation to the American market. Whilst I can decipher some of the information contained in what I have, it would obviously be easier if it was the format that I'm used to working with.
I guess my real query is, does the MSDS that I'm supplied with need to be in the format specified in the above regulations and if so is it my supplier or the original manufacturer who are obliged to provide it in this format?
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Rank: Super forum user
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I wouldn't get too concerned about the precise legalities of MSDS.
On a practical note, I assume you are in the UK etc - so treat foreign MSDS with some caution as for example other nations may have different acceptable exposure limits if considering personal exposure limits.
From the flammability point of view, if relevant, different temperature ranges/classifications may ocurr - so you may end up classifying a flammable substances with the wrong rating - this can be important when underaking DSEAR assessments and Hazardous Area Classification & Zoning.
I have seen examples where the wrong T Class has been specified when buying equipment, for use in a hazardous area - all because a foreign MSDS was used in he first place when establishing material classes.
Generally foreign MSDS are ok, just treat with some caution.
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Rank: Super forum user
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Work from here http://www.hse.gov.uk/coshh/basics/datasheets.htm
It's an interesting point you raise because I have had MSDS sheets from UK suppliers which completly omitted very significant risks. On one in particular it stated non hazardous and no respiratory masks were required etc., and yet when the product was used as per normal use it turned out to be an Oxygen scavenger and you could not breathe near it. When I contacted the supplier they re issued the MSDS with hazard labels, type of masks to be worn etc. Now as I had a second MSDS with them which was an issue we discussed things in more detail and basically they just buy into a external data base and this gives them a facility to type in a substance/chemical and the data sheet is then generated and issued and without too many checks by the company in question. This is a well known UK company who advise the HSE in a high risk area, but which is not related to the two products which we were supplied with. In addition to this we are now receiving MSDS sheets from other suppliers for actual non hazardous products and which are 50 pages long and yet provide blank data tables or else detail information on testing on mice/rats etc. Authorities are good at bringing out lots of regulations which employers need to wade through, or else result in lots of information which businesses need to wade through, but are not quite so good at making sure those who supply information keep to a standard which is usable by the average person. I think the EU struggles with the Reasonably Practicable term. Regards.
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Rank: Super forum user
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OK fscott - here it comes! I'll be gentle and please forgive me if I simplify just a little - I'm not going to re-write all the legal requirement or guidance.
JJ provides some useful tips in the previous post
1 - All substances and materials MUST have an EU compliant SDS no matter where they originate - derived from REACH Reg 5. Compliant means only EU acceptable data and presentation.
2 - A US, Canadian or Australian [or anywhere else for that matter] must be compliant with the REACH standard for EU compliance.
3 - Anyone that imports into the EU must have a permanent office within at least one of the EU countries - they are the piece of the organisation that can be "got at" if the law is broken and will be the clients official contact.
4 - CHIP has been obsolescent since 2008 and will be totally replaced by CLP by July 2015. CLP has some subtle changes to CHIP - especially pictograms.
5 - The SDS is only valid for the article to which it refers in the state that it's provided - once you start burning it's irrelevant! This is where you knowledge of respiratory hazards from burning will come into play.
I'm sure that others will have more to add - enjoy!.
Frank Hallett
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Rank: Super forum user
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Personally I am very belligerent when any supplier provides anything that is:
1) Not in English (UK) language
2) To an accepted UK(EU) format e.g. DPD, CLP
3) Is merely a forwarding of a manufacturer / distributors SDS without the addition of their contact details
There are so many global differences in classification criteria & thresholds / work place exposure limits / flammability ranges etc. that even when the Globally Harmonised System does become truly global the adaptation variations will remain on a nation by nation and continent by continent basis.
Remind the supplier of their obligations under REACH to supply suitable and sufficient information in support of their product - If they come back blankly change supplier.
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Rank: Super forum user
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Personally I am very belligerent when any supplier provides anything that is:
1) Not in English (UK) language
2) To an accepted UK(EU) format e.g. DPD, CLP
3) Is merely a forwarding of a manufacturer / distributors SDS without the addition of their contact details
There are so many global differences in classification criteria & thresholds / work place exposure limits / flammability ranges etc. that even when the Globally Harmonised System does become truly global the adaptation variations will remain on a nation by nation and continent by continent basis.
Remind the supplier of their obligations under REACH to supply suitable and sufficient information in support of their product - If they come back blankly change supplier.
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Rank: Super forum user
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Hi westonphil
The situation that you describe with your provider fails the test for "legal" & "compliant" in so many ways! As for the others with blanks - them's the rules if it's a REACH product, but if it's not, they're just identifying how little they know about the SDS requirement.
If it contains data relating to animal tests, look to see which non-EU country it originated in!
For shedloads of additional info go to the HSE website and search for REACH, CLP, SDS; and go to the Chemical Hazard Communication Society and have a look there!
The providers have nowhere to go here - they are deemed to know what is required and how to present it!
Unfortunately, those recipient organisations that rely upon their providers are also vulnerable in a range of ways because they are deemed to know as well.
Roundtuit is correct in his response - but it begs the wider question of individual organisation competence & awareness.
It would have helped if HSE had made REACH, CLP & SDS requirements rather more high-profile; but there really is loads of info there.
Frank Hallett
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Rank: Super forum user
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Welding consumables are in a rather different category from solvents and laboratory chemicals. For them, one of the key things is the composition of the fume. This depends on several factors: the composition of the consumable, the composition of the item you are welding, the welding process and parameters and the composition of the shielding gas (where appropriate) or the flux (also where appropriate).
In my experience MSDSs from the major suppliers of welding consumables are quite helpful.
What are you welding, and how?
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Rank: Super forum user
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They have a duty to supply in accordance with EU legislation and if they don't they are breaking the law. Simple as that really.
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