Lots of times details are decisive when it comes to chemical legislation.
Here's a simple case regarding essential oils that happened earlier this week.
Let's start with an e-mail I received ...
"I am struggling to get the SDS sheets for all our essential oils. Some suppliers are stalling for quite some time already, others just frankly declined. I am not sure what to do.
On the long run I will change suppliers of course, after such reactions, but what would that mean for the SDS already generated for me?
I have a lot of oil still in stock that I would need to use up first.
Would a new supplier mean we need to redo the SDS already generated? Nothing about the recipe would change, just the source of essential oil.
Also, is there such thing as general SDS for essential oils, like a database, if I cant get specific ones from a supplier?
I always see CAS numbers and such identical for different suppliers, so I thought they might be just generalised information? "
I'm sharing my answer with you as I think lots of you have the same or similar questions. So, here's what I wrote:
- Suppliers don't get to choose whether they'll send you an SDS or not. Sending you their SDSs is their obligation. We found that the following note to your suppliers work well:
Please send us Safety Data Sheets for the following products:
- > name product 1 <
- > name product 2 <
- > name product 3 <
In accordance with Article 31 of Regulation No. 1907/2006 (REACH), the supplied products must be accompanied with appropriate safety data sheets. The supplier of a substance or a mixture shall provide the recipient of the substance or mixture with a safety data sheet. The safety data sheet shall be supplied in an official language of the Member State where the substance or mixture is placed on the market.
The above-mentioned documents are required because they must be delivered to clients (downstream users – end users) according REACH Regulation and because of REACH Regulation are required by labor or chemicals inspectors during auditing, too.
Thank you for quick reply and assistance in ensuring our compliance with the legislation.
Feel free to use it and let me know how you did.
- Q: On the long run I will change suppliers of course, after such reactions, but what would that mean for the SDS already generated for me?
You have to get SDS-s from new suppliers. If the classification of new raw material is different from old one, you have to make revision of your SDS.
If we take care of them – ChemiusExpert service – then these revision is included in our service (if you send us new SDS of course).
SDSs needs to be available and in the service for minimum of two years.
This is also the requirement of legal authorities; actually, most authorities insist on five-year period, but our service defines minimum period of just two years.
- Q: I have a lot of oil still in stock that I would need to use up first.
I think this would be the best solution yes. You must label your oils according »old« SDS – Section 2.2.
- Q: Would a new supplier mean we need to redo the SDS already generated? Nothing about the recipe would change, just the source of essential oil.
Yes, new supplier needs to send you their SDSs. Here's why. Different suppliers can have different classifications of their essential oils. This depends on the data they have and must share with you.
You've mentioned CAS number bellow. Here's an example on how many different classifications is put under the same CAS. No wonder it's confusing.
But let's get back to the main part. The important thing is what classification your supplier gave to that essential oil you're using because this is the basic information used for mixture classification.
- Also, is there such thing as general SDS for essential oils, like a database, if I cant get specific ones from a supplier?
You can see from the answer above that details are important and therefore you can't just get »general« SDS for essential oils.
- I always see CAS numbers and such identical for different suppliers, so I thought they might be just generalised information?
I would agree with your idea of generalised information but unfortunately the reality is different. Here's that example of orange essential oil again.
You see how these little details mean all the difference in the world.
Hope my answers help in clearing some misunderstanding around CAS numbers and classification of essential oils.