Ever heard of a saying “Small leaks sink great ships”?
Today, I want to share a recent story that highlights the truth behind this saying.
Let me start by asking you two quick questions:
- Do you send English SDSs to all your customers?
- Are you using the same English SDSs for your UK and European clients?
If your answer is yes, then this real-life case could save you tons of time, money and hard-earned reputation.
Recently, we worked with a company that was sending English SDSs to all their clients. However, some of their EU clients flagged an issue: the emergency number listed on the SDSs was incorrect for their country. Specifically, the number was either 111 or 999, which are used in the UK, but not in the EU.
This tiny detail was the reason, their EU clients refused to accept the SDSs and, consequently, the products as well.
When we reviewed their SDSs, we found that they had been adjusted to fit the UK regulations. These include details, such us – you guessed it - phone number. In SDSs for the UK, the correct emergency number to list is 111.
On the other hand, 999 number in UK remains the number for serious emergencies where an immediate response is needed, such as life-threatening situations. But it's not typically listed on an SDS, as SDS emergency numbers are usually for handling chemical exposures or incidents rather than general emergencies.
Do you see now how this small, almost insignificant detail sank this company’s sale?
This company was sending out SDSs adjusted to fit UK regulations. However, these SDSs are not OK for EU countries.
In fact, this goes beyond just the emergency number. There are other member state-specific requirements to consider. For instance, Section 8 of the SDS, which deals with exposure controls and personal protection, contains limit values that vary by country. It is like they say- the devil is in the details.
Now the question remains – is it even possible to prepare an English SDS that could be valid for all EU countries?
For example, our clients often ask us to prepare a "general" English SDSs, meaning that the SDS is prepared in English (and the emergency phone number is 112 – since this is a general emergency number for all EU). Since everybody understands English and you can get the emergency help needed by calling 112, you should be OK. Right? Wrong.
Let me explain. First, let’s look at emergency number 112. It's accurate that 112 is a general emergency number in the EU, but for SDSs, specific poison center numbers or other designated contacts should be used. Each country has its own requirements for what emergency contact should be listed on the SDS.
Second, the language itself is also the problem. The SDSs must be in the official language of the country. You cannot even notify the product in the country without having an SDS in official language. Furthermore, the label on the product must be prepared in accordance with the SDS and must also be in the official language.
Additionally, the REACH Regulation requires you to provide the SDS in the official language of the country. Moreover, both chemical and workplace inspections could result in sanctions if you use SDSs that are not in the official language.
And finally - it’s important to note that not everyone in every EU member state speaks English. In fact, it can often be quite difficult to find English speakers in many EU countries. Providing crucial hazardous information in a foreign language could put people in dangerous situations. Now that could get in you in real trouble.
So, what are our final thoughts and recommendations regarding the “general” English SDS?
While your buyers might accept a general English SDS, they would need to translate it themselves and ensure that the SDS complies with local regulations. If this approach works for you and your buyers, providing general English SDSs could be an option. While having general SDSs might seem more cost-effective it certainly has its disadvantages.
You need to be aware that English SDSs are not actually valid in any EU member state and are considered informational only. This means they do not meet the legal requirements for compliance, which could lead to limitations and potential negative surprises for your buyers.
I hope this was helpful to you and that it helped you seal one such potential leak.
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