Good Afternoon H&S Gurus,

Regarding COSHH usage, Can I please ask the answer of how long material safety data sheets are valid for/when they expire in the UK?

It appears everywhere I research this I am getting mixed answers, being either:

a) "There is a duty to provide an adequate upto date SDS", irrelavant of date. i.e if nothing changes, a 2010 SDS sheet can still be valid today and suitable for COSHH assessment to be produced.

b) SDS Must be reviewed or changed every 3 years by manufacturer. If not they are not compliant.

c) Minimum of reviewed every 5 years by manfacturer or they are not compliant.

2009 is when the new COSHH logos were applied.

THANK YOU

Do not confuse COSHH Regulations (workplace assessment) with the Classification, Labelling and Packaging Regulations.

A valid EU/UK SDS will only reference REACH (EC) 1907/2006, CLP (EC) 1272/2008 and the current enabling regulation EU 2015/830. So no longer valid:

any MSDS prepared in accordance with CHiP as this was withdrawn in 2015.

any CLP SDS prepared according to EU 453/2010 as this was withdrawn June 2017.

EU 2015/830 will be replaced by the end of this year with EU 2020/878 but there will be a derrogation until the end of 2022 (this new format includes adding Unique Formula Identifiers for Poison Centre notifications).

A timed validity is impossible to set due to constant update of the regulations and changes in the information held regarding specific substances and changes to the restriction and authorisation lists.

Take a look at the ECHA web site where there are links to the guidance and regulations https://echa.europa.eu

Safety Date sheets for COSHH?

“(e) which, not being a substance falling within sub-paragraphs (a) to (d), because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health” - COSHH Regulation 2 (1) Interpretation

===

ACoP for COSHH 6th edition:

Paragraph 10 - 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.

===

Also from ACoP:

When deciding whether the substances used or produced in the workplace are covered by COSHH, employers should also consider the following:

Different forms of a substance may present different hazards, eg substances may not be hazardous in solid form but may be hazardous when ground into fine powder or dust that can be breathed into the lungs.

Nanoparticles (ie particles less than 100 nanometers) may be more toxic than larger particles of the same chemical substance.

Impurities in a substance can make it more hazardous, eg crystalline silica is often present in minerals which would otherwise present little or no hazard.

Some substances have a fibrous form which may present a potentially serious risk to health if the fibres are of a certain size or shape.

Some substances have a known health effect but the mechanism causing it is unknown, eg certain dusts of textile raw materials cause byssinosis.

Exposure to two or more substances at the same time or one after the other may have an added or synergistic effect.

Epidemiological or other data, eg reports of illness due to new and emerging agents, indicate that a biological agent that does not already appear in The Approved List of biological agents could nevertheless cause a hazard to health.

One-off, emergency situations arising out of the work activity, such as a dangerous chemical reaction or fire, could foreseeably produce a substance hazardous to health.

===

A study by the European Chemicals Agency (ECHA), the organisation responsible for REACH, found that of 1,181 companies they inspected in 29 countries, mostly ‘downstream users’, i.e. formulators, regarding compliance with REACH, 52% were producing safety data sheets described in the study as ‘deficient’. - ECHA – REACH-EN-FORCE2

===