Epy

WHAT IS THE REGULATION 2020/878?

This Regulation contains the current requirements for compiling Safety Data Sheets.
Regulation (EU) 2020/878 of the committee of the 18th June 2020, which modifies Att. II of REACH.

WHICH STANDARDS ARE MENTIONED IN THE DRAFT OF A SAFETY DATA SHEET?

In preparing the Safety Data Sheet, the normative reference that was applied for the classification of chemical substances and mixtures should be indicated.

  • Regulation 1272/2008

It is sufficient to include the lettering “and further adjustments” rather than listing all of the updated norms.
Furthermore, there should also be indicated all the regulations in force which are related to: emissions, VOC, Restrictions and Authorisations according to REACH, detergents, import/export outside the EU, when applicable.

WHAT SKILLS MUST THE PERSON PREPARING THE SDS HAVE?

The Safety Data Sheet must be completed by a competent person, taking into account the specific needs of the public users, if known.
The people that place substances and mixtures on the market must be ensured that the competent people have received appropriate training, including refreshers.
State on page 1.3 the email address of the competent person who is responsible for the safety data sheet.

WHO IS RESPONSIBLE OF CREATING A SAFETY DATA SHEET?

It is the (natural or legal) person responsible for placing the product on the market. Therefore, it can be the manufacturer, but also an importer when the product comes from a country outside of the European Community. It can also be a distributor or reseller in general, if they market the product with their own name.

IN WHICH LANGUAGE SHOULD THE SDS BE PREPARED?

The Safety Data Sheet must be supplied in an official language of the State where the substance or preparation is placed or on the market, according to article 31 of REACH Regulation.

WHEN SHOULD THE SDS BE PROVIDED?

The Safety Data Sheet must be imperatively provided before or simultaneously with the first delivery to the recipient, in the following cases:

  • The substance or mixture is classified as dangerous according to the Regulation 1272/2008;
  • The substance is PBT or vPvB ( see Annex XIII);
  • The substance is included in Annex XIV ( substances subject to authorization, except for a) and b)).

The procurement or the SDS is free of charge in paper or electronic format.
The SDS must be consistent with the data and information contained in the Chemical Safety Report ( CSR).

IS IT TRUE THAT I HAVE TO PROVIDE A SDS OF A PRODUCT DEEMED NON-DANGEROUS?

The Safety Data Sheet has to be provided at request of a Customer if a mixture does not meet the criteria for classification as hazardous in accordance with Titles I and II of Regulation (EC) No. 1272/2008, but contains:

  1. in an individual concentration of >= 1% by weight at least one substance posing human health or environmental hazards;
  2. in an individual concentration of >= 1% by weight at least one substance that:
    1. is classified Carcinogenic in Category 2; 
    2. is classified Toxic for reproduction in Category 1A or 1B or 2 or has effects on or via lactation,;
    3. is classified Respiratory or skin sensitization of Category 1;
    4. Persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) in accordance with the criteria set out in Annex XIII;
    5. included in the Candidate List for reasons other than being classified as dangerous for health or environment;
    6. has endocrine disrupting properties for health o environment, Cat. 2
  1. a substance for which there are Community workplace exposure limits

The supply of SDS is free of charge in a paper or electronic format.

WHEN ARE WE OBLIGED TO UPDATE THE SDS?

Suppliers have to update the Safety Data Sheet without delay in the following circumstances:

  • as soon as new information becomes available that may affect the risk management measures or new information on dangers;
  • when an authorization has been granted or refused;
  • when a restriction has been imposed.

Reach regulation states that the SDS  has to be updated “without delay”.

The new version of the information, dated and identified as “Revision: ( date)” is provided free of charge on paper or electronic format to all former recipients to whom they have supplied the substance or preparation to within the preceding twelve months. Any updates following the registration of a substance must include the registration number of the substance.