Rank: Forum user 
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Good afternoon, I am looking for some advice on why some products and chemicals in their finished state do not require a safety data sheet. As a pharmaceutical distributor, we do not own the products stored, we simply hold and distribute a multitude of variations on behalf of clients. As a duty, we request all SDS's from our clients to ensure that the storage and handling conditions are adhered to for employee safety under COSHH and also from an environmental protection perspective should a spill or release occur. However, it is understood that certain products such as veterinary, some medicines, make up etc are exempt from supplying a SDS when the product is in its finished state. If there could be any advice or guidance on this that would be greatly appreciated Kind regards Nicole
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Rank: Super forum user 
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REACH regulation EC 1907/2006 Article 31 applies: Requirements for safety data sheets
1. The supplier of a substance or a ►M3 mixture ◄ shall provide the recipient of the substance or ►M3 mixture ◄ with a safety data sheet compiled in accordance with Annex II:
(a) where a substance or mixture meets the criteria for classification as hazardous in accordance with Regulation (EC) No 1272/2008; or
(b) where a substance is persistent, bioaccumulative and toxic or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII; or
(c) where a substance is included in the list established in accordance with Article 59(1) for reasons other than those referred to in points (a) and (b).
So basically if it is not classified as hazardous including to human health or damaging to the environment there is no obligation to provide a Safety Data Sheet. Article 2 of the same regulation stipulates which products this applies to.
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 4 users thanked Roundtuit for this useful post.
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Rank: Super forum user
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REACH regulation EC 1907/2006 Article 31 applies: Requirements for safety data sheets
1. The supplier of a substance or a ►M3 mixture ◄ shall provide the recipient of the substance or ►M3 mixture ◄ with a safety data sheet compiled in accordance with Annex II:
(a) where a substance or mixture meets the criteria for classification as hazardous in accordance with Regulation (EC) No 1272/2008; or
(b) where a substance is persistent, bioaccumulative and toxic or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII; or
(c) where a substance is included in the list established in accordance with Article 59(1) for reasons other than those referred to in points (a) and (b).
So basically if it is not classified as hazardous including to human health or damaging to the environment there is no obligation to provide a Safety Data Sheet. Article 2 of the same regulation stipulates which products this applies to.
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4 users thanked Roundtuit for this useful post.
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Rank: Super forum user
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Nicole If the product does not contains substances assigned a Hazard Statement then a safety data sheet is not required. However, what is often overlooked is the requirement according to the COSHH ACoP:
“Employers should regard a substance as hazardous to health if it is hazardous in the form in which it may occur in the work activity. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust.” What is often overlooked is also the requirement under the Health and Safety at Work etc. Act 1974, where section 6(4) includes the following: It shall be the duty of any person who manufactures, imports or supplies any substance for use at work:-
(c) to take such steps as are necessary to ensure that there will be available in connection with the use of the substance at work adequate information about the results of any relevant tests which have been carried out on or in connection with the substance and about any conditions necessary to ensure that it will be safe and without risks to health when properly used. HSE has prosecuted chemical suppliers based on the lack of information provided under this section to someone or organisation they have supplied. Hope this provides some clarification but PM me if you need more.
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1 user thanked chris.packham for this useful post.
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