Today, I would like to share with you the remaining three answers to 6 FAQs that I get asked every day. If you missed the first part of this post, you can read it here (link).
Now, let's focus on the remaining three questions and answers.
- Item 1.3: Manufacturer – Does the actual manufacturing site for a specific chemical have to be indicated on the safety data sheet?
- Item 1.3: Supplier – Does the supplier (invoice issuer) of the chemical have to be indicated on the safety data sheet? Example: XYZ company issues all safety data sheets in Italy, specific materials are sold via its sales branch in Germany – does the supplier XYZ company in Germany have to be indicated for those safety data sheets?
- Item 1.3: The contact info about a competent person responsible for safety data sheets: can this section contain a general e-mail address that can be seen by the wider public (example: manager.sds@XYZcompany.com) or does it have to contain a specific e-mail address of a contact person, e.g.: John.Smith@XYZcompany.com?
Questions 3 to 6 are quite alike, so I have combined all replies.
The safety data sheet has to contain information about one of the suppliers. REACH Regulation No. 1907/2006 defines the supplier as follows: "supplier of a substance or a preparation: means any manufacturer, importer, downstream user or distributor placing on the market a substance, on its own or in a preparation, or a preparation."
Item 1.3 of Annex II of REACH Regulation (Company/undertaking information) stipulates:
"The supplier, whether it is the manufacturer, importer, only representative, downstream user or distributor, shall be identified. The full address and telephone number of the supplier shall be given as well as an e-mail address for a competent person responsible for the safety data sheet.
In addition, if the supplier is not located in the Member State where the substance or mixture is placed on the market and he has nominated a responsible person for that Member State, a full address and telephone number for that responsible person shall be given.
For registrants, the information shall be consistent with the information on the identity of the manufacturer or importer provided in the registration. Where an only representative has been appointed, details of the non-Union manufacturer or formulator may also be provided."
A dedicated general (not personal) e-mail address should be used as an e-mail address of the competent person, responsible for the safety data sheet, which can also be seen and used by the general public – for instance: SDS@XYZcompany.com. It is not specifically required that the competent person must be located in the territory of the European Union or the European Economic Area.
Besides the legal requirements, mentioned above, the "SECTION 16: Other data" on the safety data sheet can contain an additional department/contact person responsible for the content of the safety data sheet (an internal or external safety and health adviser, including the telephone number as the minimum data required for contact).
The safety data sheet does not have to contain the name of the natural person; the "supplier" is a natural or legal entity.