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Can a Safety Data Sheet contain non-mandatory additional data?
Today I am going to share with you a specific question on compilation of Safety Data Sheets (SDS).

We have been receiving this question ever since the introduction of the SDS in Chemius have been harmonized with the COMMISSION REGULATION (EU) 2020/878, which prescribes the form of the SDS.

The question usually goes like this:

“Can you please remove subsection 12.8 from MSDS as this is not in line with EU MSDS requirements?”

My answer usually goes like this:

“Thank you, we get this question a lot.

In fact, this subsection is a part of the official “Guidance on compilation on Safety Data Sheets” issued by ECHA. The English version can be accessed directly here. You need to go to page 107 and read where it says:  

              “An example of how the structure of this section could look is given below:

              Among other subsections, it also says “12.8 Additional information.

The regulation on SDS only contains mandatory sections and subsections, which must be included. Including additional subsections, if the specified format is followed, is not against the regulation.

In other words, if you have additional relevant data, you should always add it. Therefore, a Safety Data Sheet may contain non-mandatory additional data.”

If you are wondering how to determine if your received SDS is in fact compliant with the COMMISSION REGULATION (EU) 2020/878, here are Three simple methods for quickly determining whether received safety data sheets comply with Regulation (EU) 2020/878.

If you get such requests regarding SDS from your clients and do not have the time to deal with them, we can help you. Simply write us to info@bens-consulting.eu and our team of SDS experts will check how we can help you and offer a solution.

*Source of picture: ECHA, Guidance on the compilation of safety data sheets, Version 4.0, December 2020, page 108

Disclaimer:
Information on this blog is prepared with utmost care, but it is not about (chemical) consulting, and the provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can write to us at bojan.dimic@bens-consulting.eu
SDS | January 10, 2024

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