Posted By GavinR Hi, i have a few MSDS sheets coming through from sister plants in US for substances they produce on site. These are only in a US format. The MSDS has the component parts listed and guide percentages but not confirmed. I have used ASL and now COSHH essentials to help get the general controls however the question i have is how do you apply the R phrases to this substance? It is made up of 11 chemicals which all have a range of R phrases assigned. If i apply all the R phrases i have 13 R phrases for this substance. Some R phrases are assigned to chemicals that are no more than 4% and some even as low as 2%. I do not wish to discount these simply from their low %. Does anyone have any advice please?

Posted By NJS Pardon my ignorance in chemical processing/use but what are MSDS sheets? NJS

Posted By Nick Patience No such thing as a stupid question - that is how we learn. MSDS = Materials Safety Data Sheet, they are a requirement from OSHA (Occupational Health and Safety Administration in the USA)for Hazard Communication.

Posted By Bob Youel your supplier, even where they are a sister company, should supply these to you in the appropriate form even where import is only for your use Where you convert one system to another you MUST be competent to do so - noting that disease can wait a long time to manifest itself and then come back to bite you previous postings have given you some good advice so please follow it whilst at the same time put the onus back to the supplier

Posted By GavinR Hi, Thanks for your replies. I have used the approved supply for all the individual chemicals as stated in the original posting and through this i have the R phrases, etc identified. It was a question of how the % of the chemical within the final product effect the overall R-Phrasing and controls for the product. I have completed an initial COSHH based on the US MSDS format and our current controls are all engineering measures to reduce exposure during storage, handling, use and disposal. Personel monitoring will also be completed along with Health surveillance. I treating it as worst case scenario. I have asked many times before about the product of the MSDS in an EU format but having no progress onthis matter. I'm also having the powder A/B Classication tested for DSEAR purposes and again this is another reason why i need to have EU MSDS available. Thanks for the advice.

Posted By Chris Packham Remember that a risk assessment for COSHH based on risk phrases may not be a valid risk assessment. See paragraph 13 of the ACoP for COSHH on this. Chris

Posted By b318isp My understanding under REACH is that the onus is on the supplier to provide this information to you on the basis that it is being used for its normal function (and if not, you have to obligation to tell them). As you have previously got nowhere on this in the past, you may have to escalate that there is non-compliance to EU requirements in this area, and as a result, you should not be using them. This may accelerate an action in the US to sort this out.

Posted By NJS paulw71, sorry for not being up to date with you acronym system! I am fully aware of what data sheets are, i had just never heard of them being called MSDS's, again sorry! Nick Patience, thanks for your answer, I guess your name reflects your character.