Are Material Safety Data Sheets in the U.S. Good to Ship Products to the EU?

A Material Safety Data Sheet (MSDS), also called Chemical Safety Data Sheet (CSDS) in some parts of the world, or simply Safety Data Sheet (SDS) in the EU, is a document, generally with a regulated format and content, to convey information on the risk and safety measures associated with a chemical product. Suppliers of chemicals are usually required to provide a SDS to the users of chemicals, and sometimes also to authorities.

In the EU, SDS are regulated by the REACH Regulation, which describes in great detail how the document must be compiled.

However, the fact that the rules on SDS are provided in REACH, which is a Regulation directly applicable in all the EU Member States, does not mean that a single SDS will fit across all countries. REACH provides for variations across countries and requires reviewing the specifics in each state.

The most obvious variation is the language. The SDS must be provided in the language(s) of the country. So, for example, an SDS used in Germany should be in German. Attention must be paid however to countries were there is more than one official language. In Belgium for example, where official languages are Dutch, French and German, a chemicals supplier will have to take into consideration the languages understood by the user. If various users speak different languages, the supplier will have to provide version of the SDS in the official languages.

Aside from the language, there are other types of variations, like the emergency telephone number (required in Section 1 of a REACH-compliant SDS). Safety Data Sheets need to display the phone number that a chemical user may call to obtain advice on emergency measures in case of an accident involving the chemical. A chemical supplier may choose to indicate the number of the local anti-poison center–where there is one. Indeed, not all EU countries have an anti-poison center.

Other examples of variations between SDS for different EU countries include the occupational exposure limits (OELs, required in Section 8). The OEL for a given chemical substance generally varies from one country to another. A SDS must display the OEL applicable in the country where the chemical is used. REACH-compliant SDS must also refer to local regulations, for example as regards to the rules for waste disposal (regulating how the chemcials packaging and residues must be disposed of).

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An Overview of Enhesa’s Free Webinar on Occupational Exposure Limits

What do you need to know about occupational exposure limits?

Do you know which chemicals in which countries currently have OELs?  Which chemicals are being considered? Are you aware of the differing exposure limits in each EU Member State? What are the consequences for non compliance in different countries? The impact of REACH on OELs? How to balance compliance, financial obligations and health issues?

Over 300 attendees tuned into hear our expert speakers, Laura Smith and Brett Parnell, discussing the following topics:

  • EU Regulation of OELs
  • Member Countries’ differing  implementation schemes
  • Proposed 3rd Directive on Indicative Exposure Limits including insight into potentially controversial chemicals  (i.e. formaldehyde)
  • Reach Designated No Effect Limits (DENLs) and their impact on OEL regulations
  • Suggestions on how to address the challenge of creating a global standardized production process that addresses differing legal requirements and contradictory advice from manufacturers.

Laura Smith and Enhesa director, Thierry Dumortier, also answered questions at the end of the session. Some of the questions included the following:

  • What do you envision will be the process for harmonization of OELs and DNELS, etc?
  • What advice would you give to companies who operate in more than one EU member state or have mobile work forces who work across states in respect of OEL compliance?
  • What impact if any do you think the new exposure scenarios will have on businesses? How do you think this will be enforced?

Here are some quotes from some of our satisfied attendees:

  • It was a great presentation and the session was very useful for me and our company. Global REACH Manager, Opel
  • … was very informative and very well presented. Please extend my compliments to the Enhesa team for a job well done (as usual).
    Product Regulatory Analyst Corporate Product EHS Lead, Applied Materials
  • We at PPG Corporate Occupational Health thought this was one of the best and most informative webinars we have attended.
    PPG Corporate Occupational Health, PPG

For a copy of the presentation and access to the webinar recording, please contact us at webinars@enhesa.com