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knotty  
#1 Posted : 22 November 2021 15:09:58(UTC)
Rank: Forum user
knotty

My employer sells (amongst other things) chemicals around the world. 

I am being increasingly inundated with requests from companies who charge their clients to set up "COSHH databases", asking me to supply SDS's or confirm if the ones they have are up to date.

Of course, we supply SDS's to our customers as required, and also make them available in all relevant languages, on our website.

Is there any obligation to provide them to these third party organisations, or can I simply return a standard email pointing them to the website, and remind them that any updates will be provided to the purchaser?

craigroberts76  
#2 Posted : 22 November 2021 15:23:50(UTC)
Rank: Forum user
craigroberts76

If you make them then you have to provide them, I'm always chasing them down as we buy off the shelf products that dont come with them.

Why not simply put a COSHH section on your website? I love it when a site has one, easier for everyone.

A Kurdziel  
#3 Posted : 22 November 2021 15:24:04(UTC)
Rank: Super forum user
A Kurdziel

Article 31 of REACH says” The supplier of a substance or a mixture shall provide the recipient of the substance or with a safety data sheet compiled in accordance with Annex II:” So the legal obligation is only to people in the supply chain, not to 3rd parties. If the  database companies  are charging their customers for this information, I can’t see anything wrong(or illegal) with charging them for supplying the SDS.

thanks 2 users thanked A Kurdziel for this useful post.
knotty on 22/11/2021(UTC), Kate on 22/11/2021(UTC)
knotty  
#4 Posted : 22 November 2021 15:36:40(UTC)
Rank: Forum user
knotty

Originally Posted by: craigroberts76 Go to Quoted Post

If you make them then you have to provide them, I'm always chasing them down as we buy off the shelf products that dont come with them.

Why not simply put a COSHH section on your website? I love it when a site has one, easier for everyone.


 All the SDS's are on the website. In addition, we email them to customers, and have a full record of who has received which ones.

But these guys want me to do the work for them, so they can charge a fee to the client..

Edited by user 22 November 2021 15:38:27(UTC)  | Reason: ffs

A Kurdziel  
#5 Posted : 22 November 2021 15:51:58(UTC)
Rank: Super forum user
A Kurdziel

Who owns the copyright on an SDS? Not as stupid as it sounds. If you look at the small print on a bank note you will see that the copyright belongs to the Bank of England. The broadcasters  had copyright on their schedules which is why we had to buy the Radio Times and TV Times separately. Many, many years ago it was ruled that the  schedules of football matches were copyright of the Football league which is why the pools companies had to pay  for the right to print off next week’s match schedule.  So why not an SDS except of course for those people who have a statutory right to receive one.

Roundtuit  
#6 Posted : 22 November 2021 16:20:01(UTC)
Rank: Super forum user
Roundtuit

These parasites need removing - they take a clients portfolio of SDS, rearrange content and call it a COSHH assessment. They then harass the supplier for updates. Most do not even bother to see if they already have multiple (including newer) copies of the same document from different customers.

Even with the more professional providers who actually present a letter of authority on behalf of their client I refuse to provide any documentation as the legal obligation is along the supply chain to the customer.

As to posting to a web site this is classed as passive distribution and is not in accordance with the requirements of the regulation on top of which companies often fail to adequatley monitor and update content on the web - feel free to have a look around some major DIY company web sites at their available SDS many are still in the old CHiP format and not the latest manufacturer version.

thanks 4 users thanked Roundtuit for this useful post.
A Kurdziel on 22/11/2021(UTC), knotty on 25/11/2021(UTC), A Kurdziel on 22/11/2021(UTC), knotty on 25/11/2021(UTC)
Roundtuit  
#7 Posted : 22 November 2021 16:20:01(UTC)
Rank: Super forum user
Roundtuit

These parasites need removing - they take a clients portfolio of SDS, rearrange content and call it a COSHH assessment. They then harass the supplier for updates. Most do not even bother to see if they already have multiple (including newer) copies of the same document from different customers.

Even with the more professional providers who actually present a letter of authority on behalf of their client I refuse to provide any documentation as the legal obligation is along the supply chain to the customer.

As to posting to a web site this is classed as passive distribution and is not in accordance with the requirements of the regulation on top of which companies often fail to adequatley monitor and update content on the web - feel free to have a look around some major DIY company web sites at their available SDS many are still in the old CHiP format and not the latest manufacturer version.

thanks 4 users thanked Roundtuit for this useful post.
A Kurdziel on 22/11/2021(UTC), knotty on 25/11/2021(UTC), A Kurdziel on 22/11/2021(UTC), knotty on 25/11/2021(UTC)
Roundtuit  
#8 Posted : 23 November 2021 08:45:55(UTC)
Rank: Super forum user
Roundtuit

Those who subscribe to these services should remember you (not the provider) are liable and accountable.

Wouldn't that subscription be better invested in the training & development of your employees?

thanks 6 users thanked Roundtuit for this useful post.
A Kurdziel on 23/11/2021(UTC), Dazzling Puddock on 23/11/2021(UTC), knotty on 25/11/2021(UTC), A Kurdziel on 23/11/2021(UTC), Dazzling Puddock on 23/11/2021(UTC), knotty on 25/11/2021(UTC)
Roundtuit  
#9 Posted : 23 November 2021 08:45:55(UTC)
Rank: Super forum user
Roundtuit

Those who subscribe to these services should remember you (not the provider) are liable and accountable.

Wouldn't that subscription be better invested in the training & development of your employees?

thanks 6 users thanked Roundtuit for this useful post.
A Kurdziel on 23/11/2021(UTC), Dazzling Puddock on 23/11/2021(UTC), knotty on 25/11/2021(UTC), A Kurdziel on 23/11/2021(UTC), Dazzling Puddock on 23/11/2021(UTC), knotty on 25/11/2021(UTC)
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