What Are COSHH Data Sheets?
Updated: May 4, 2020
Safety Data Sheets (SDS), previously known as Material Safety Data Sheets (MSDS), are a requirement of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH.)
REACH are a body of regulations put into place in June 2007 and are the controlling system for chemical use and handling in Europe.
Since REACH took over control of the previous system, the Chemicals Hazard Information and Packaging for Supply Regulations 2002 (CHIP), it has been changed to adhere to the newer Classification, Labelling and Packaging Regulation (CLP) from 2009.
The older CHIP system required that manufacturers of chemicals had to identify and document all hazards associated with their products.
This was to be achieved by the labeling and supply of safety data sheets before the product enters the chain of supply.
The newer CLP regulations dictate that all chemical products must all undergo a change of labeling.
The new labels have moved away from their typical orange square design and are now designed as red marked diamonds.
The actual warning image in the centre of the labels remains largely the same, however.
Safety data sheets also now require a signal word and hazard and precautionary statements.
While the regulations have been in force since 2009, all companies were given a 2-year grace period, from June 2015, in which to complete their switch-over to the CLP system.
This means that after the month of June in 2017, all chemical products on the market should be classified under the new regulations.
One of the main aspects of the older system, safety data sheets, are still in use through the CLP regulations.
The guidelines for creating them, however, were updated to match the newer system.
Do You Need To Author And Supply Safety Data Sheets?
Safety data sheets are crucial documents for the safe use, handling and supply of chemicals. Every single chemical in existence has this set of guidelines.
They are designed to ensure that anyone who comes into contact with chemicals in a workplace, or anywhere else, can do so without risk of harm to themselves or their environment.
Safety data sheets aren't in themselves a risk assessment. A safety data sheet will, however, contain all of the necessary information for an employer to carry out their risk assessment.
This is a lawful requirement under the Control of Substances Hazardous to Health (COSHH).
Safety data sheets are mandatory for any hazardous chemicals, or for those chemicals which are not hazardous in themselves but contain even small amounts of a hazardous substance.
You need to supply safety data sheets if:
You supply a: (a) substance or a mixture that is classified as hazardous under the CLP Regulation (EC) No 1272/2008; or (b) a substance that is persistent, bioaccumulative and toxic (PBT), or very persistent and very bioaccumulative (vPvB) as defined in Annex XIII of REACH; or (c) a substance that is included in the European Chemicals Agency’s 'Candidate List' of substances of very high concern for reasons other than (a) and (b) given here.
You are a supplier and your customer requests a SDS for a mixture that is not classified as hazardous under the CLP Regulation (EC) No 1272/2008, but contains either: (a) a substance posing human health or environmental hazards in an individual concentration of ≥ 1 % by weight for mixtures that are solid or liquids (i.e., non-gaseous mixtures) or ≥ 0.2 % by volume for gaseous mixtures; or (b) a substance that is carcinogenic category 2 or toxic to reproduction category 1A, 1B and 2; skin sensitiser category 1; respiratory sensitiser category 1; or has effects on or via lactation or is persistent, bioaccumulative and toxic (PBT) or very persistent and very bioaccumulative (vPvB) in an individual concentration of ≥ 0.1 % by weight for mixtures that are solid or liquids (i.e., non-gaseous mixtures); or (c) a substance on the 'Candidate List' of substances of very high concern (for reasons other than those listed above), in an individual concentration of ≥ 0.1 % by weight for non-gaseous mixtures; or (d) a substance for which there are Europe-wide workplace exposure limits. If you are a supplier to EU countries other than the UK, then you may need to supply a SDS for substances or mixtures that are not classified as hazardous where they have relevant national workplace exposure limit values.
You are a supplier of a product listed as a ‘special case’ in paragraph 1.3 of Annex 1 of the CLP Regulation (EC) No 1272/2008 for which there are labelling derogations; e.g., gas containers intended for propane, butane or liquefied petroleum gas.
You do not need to provide a SDS:
If the substances/mixtures are supplied in the UK and not classified as hazardous or considered PBT, vPvB or of equivalent concern (e.g., endocrine disruptors).
For certain products intended for the final user, e.g. medicinal products or cosmetics.
If you offer or sell dangerous substances or mixtures to the general public and you provide sufficient information to enable users to take the necessary measures as regards safety and the protection of human health and the environment. However, a downstream user or distributor can ask you to provide one.
Information required on safety data sheets:
Identification of the substance/mixture and of the company/undertaking.
Composition/information on ingredients.
Accidental release measures.
Handling and storage.
Exposure controls/personal protection.
Physical and chemical properties.
Stability and reactivity.
A SDS should be supplied in an official language of the Member State(s) where the substance or mixture is placed on the market (unless the relevant Competent Authority in the Member State(s) concerned has indicated otherwise).
In addition, SDS for substances or mixtures containing substances that have been fully registered under REACH will require inclusion of:
Registration numbers where appropriate (see also section on confidentiality provisions.)
The identified use(s) and uses advised against in section 1.
The relevant DNELs (Derived No Effect Level. The DNEL represents a level of exposure above which humans should not be exposed) and PNECs (Predicted No Effect Concentration. The PNEC represents the concentration of a chemical in any environmental compartment below which unacceptable effects will most likely not occur) for that substance in section 8.
(The above guidelines were provided by the HSE Government website)
Safety Data Sheets Emergency Contacts
It is also imperative that your safety data sheets include an emergency contact number in section 1.4.
The number in question should be operated by a competent staff member who is fully trained and, in the event of emergency can offer clear and precise information in the correct languages, to any given situation.
Emergencies can include major spillages, fire, or accidental ingestion.
While not mandatory, it is highly recommended that suppliers of safety data sheets include the advice:
"In the event of a medical inquiry involving this product, please contact your doctor or local hospital accident and emergency department"
If you're worried you may be breaching REACH or COSHH Regulations when creating and using Safety data Sheets, take my new COSHH Risk Assessor Certification™.