This is the second part of the article, where I'm busting the myths about safety data sheets (SDS) and labels, which many believe are true. However, they are simply not. Here are the first three myths from Part 1:
#1: Only inspectors read safety data sheets
#2: Safety data sheet is too long
#3: A compiled safety data sheet always applies
Now, let's write about the remaining four ...
#4: There's nothing to be afraid of, because safety data sheets have been translated by a translation agency
Let me tell you, it doesn't even help if translations are made by a certified translator.
Safety data sheets are actually not translated and a translation agency can't compile them.
Let me explain such a bold statement.
Safety data sheets are all about the suitability of the document, which must be adapted to the national legislation. Document suitability means that all information in a safety data sheet are accurate. This means that the hazardous chemical is appropriately categorised. The mixture must be appropriately categorised with regards to the composition, stated in the SDS and with regards to the substances in the SDS. Unfortunately, this is often not the case.
SDSs frequently do not contain proper H- and P-statements. Often certain P-statements are missing, when they should be indicated, for instance: "Keep out of reach of children."
We, as experts, know such regulations, but translators don't need to know them and therefore don't know what must be stated in an SDS.
Let's continue with storage classes. Translation agencies don't follow all local or EU regulations and are also not paid to do this. A translator cannot know, in which storage class a certain chemical should be categorised in accordance with recently published Regulations on technical and organisational measures for storage of hazardous chemicals. As experts in this field, we are also familiar with such information that is then appropriately stated in an SDS.
We have noticed most problems with Section 8 of the SDS, which must be adapted to Slovenian legislation. This section is supervised by the labour inspectorate. This section determines protective equipment and substance limit values for professional exposure at workplace.
Then there's also Section 14, where we often check, whether a certain UN number is appropriate. If the SDS contains a corrosive chemical or a chemical that is dangerous for the environment, we know immediately that the specific SDS must also contain a specific UN number.
These are some key pieces of information that a translation agency simply cannot know, and they represent the key obstacle on the way to compiling a suitable SDS.
We can say that we don't translate SDSs, but we harmonise them with the CLP regulations and with the categorisation in accordance with the European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR). At the same time, we warn about possible product specifics and add content that is relevant for an individual product.
That way our clients get “the best of both worlds". Firstly, a well-compiled SDS, and secondly, personal and expert advice.
I’m sure you’ll agree no translation agency can beat that.
#5: The purpose of labels is to advertise a product
A label contains all the information that a consumer needs. Such information arises from an SDS, which is the "personal identity card" of a chemical. It exactly defines what needs to be written on the label and which information a label should contain.
A label tells the consumer what hazards are connected to a specific chemical and how to handle such a chemical. There are three types of hazards considered:
- health hazard,
- environment hazard, and
- physical hazard.
The labels also contain precautionary statements. The H- statements define the type of hazard, and P-statements define how to safely use a chemical. We should be aware that – regardless of nice packaging – we are still talking about a chemical. Therefore, we need to know how to safely handle any chemical.
In case of problems or accidents the label contains the information about how to act. E.g., if you need to rinse your eyes with water, immediately consult a doctor or something else. To be slightly more dramatic, you can also read from a label whether a chemical might cause cancer. You can also learn what happens if this chemical runs into sewage, rivers or what happens in case of a spillage.
As you can see, a label contains very important and relevant information, therefore, every label is different.
#6: All safety data sheets are more or less the same
If you are referring to the prescribed format of a safety data sheet, then this is true.
But from there on, each SDS is its own "story".
An SDS contains 16 sections and is full of information that is relevant for various experts as well as users.
Our company currently manages 35,375 SDSs and I can tell you that their content is not identical at all.
This is understandable, if we know that the European Chemicals Agency (ECHA) portal contains more than 100,000 substances.
I hope that the numbers have convinced you and that you now understand that there are really numerous combinations possible.
#7: No one in our supply chain is interested in safety data sheets. Why would they interest us?
Because an SDS is the source of information for EVERYONE in the supply chain.
This means that the information about hazards and safe use of chemical travel from the manufacturer to consumer or professional user quickly and without any obstacles.
The main source of information to all parts of a supply chain is an SDS. It involves an agreed format that is used to transfer relevant information from the start to the end of the supply chain.
Information in this chain shouldn’t be lost, only upgraded, improved and adapted to various local legal regulations.
Thus, it's important that each link of the supply chain takes their obligations seriously and responsibly.
Please, have a quick look at the mentioned myths again. If we have drawn your attention and if you need my help with safety data sheets or you simply don't have the time to tackle them yourself, just let me know. Our team will be happy to help you.