Hello.  This might sound like an obvious question but i feel i'm not getting a swift answer via my employer.  We are a company that makes hundreds of different chemical products, and hence have hundreds of different raw materials.  We rely on a team (based in another country) to provide SDS for raw materials as well as the final product.  Any other company i have worked for, if a material changes classification then a new SDS is sent to us by the supplier to allow us to update our controls.  However my company's team have told us that they will not inform us if any of these materials change hazard classification due to the amount of work this would involve.  This obviously has an impact on us and we could potentially be putting our people at harm unknowingly because we have not been updated.

Apart from the moral obligation, is it written in black and white anywhere in any legislation (ieally tht also applies in the EU) about the requirement to update customers (in this case, we're the customer) when there is a change to a chemical's classification?  I need something concrete that tells them they need to do this

Article 31 of EC 1907/2006 The REACH Regulation:

9. Suppliers shall update the safety data sheet without delay on the following occasions: (a) as soon as new information which may affect the risk management measures, or new information on hazards becomes available;

The new, dated version of the information, identified as ‘Revision: (date)’, shall be provided free of charge on paper or electronically to all former recipients to whom they have supplied the substance or ►M3 mixture ◄ within the preceding 12 months. Any updates following registration shall include the registration number.

Think that pretty much covers what you are after

‘never trust the safety data sheet’

It depends what you want the safety data sheet for. In this context consider what the ACoP for COSHH states:

“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.” - COSHH ACoP (6th edition), para. 10

We purchase chemicals usually to use for a particular task. In doing so we almost certainly will change them (contaminating, mixing, reacting, oxidising, heating, etc.) and in the process change the hazard. The safety data sheet will rarely provide this information, particularly when we mix two chemicals each with their own safety data sheet. For skin there are many chemicals that will not even appear on a safety data sheet.

A risk assessment must be based on the real risk that will exist when the chemical(s) are used during the task. In my own work with skin in the working environment I see many risk assessments that do not correctly identify the risk to skin since they are not based on the real hazard.

A UK operation could be a customer, especially now that the GB is not part of the EU market - big corporate likes to shuffle its money between pots.

UK customers who import now have obligations not seen in previous EU legislation e.g. to submit Down Stream User Information to the HSE. Would be hard to submit accurate information if the company are failing to supply.

Chris P - Agreed...just charied a HAZOP where I challenged the SDS they had been useing and found some gaps...in response to the OP I would say that the full package  - the task risk assessment should be provided...if it is a more potent material then a second stage assessment of the risk should be undertaken by a Qualified Industrial Hygienist...if it is even higher risk then a toxicologist...