Often my first contact with a client starts with an email question like:
“Can you help us prepare or adapt a Safety Data Sheet (SDS)?”
The short answer is: yes. But it is always followed by a few more questions. I need some additional information to understand exactly what kind of document you need and what the right approach is.
First, I need to know which market the document is intended for — for example Bosnia and Herzegovina, Montenegro, or an EU country. If you need an SDS for the market of Bosnia and Herzegovina (BiH), then I also need to know which part of the market you plan to place your product on.
In Bosnia and Herzegovina, different rules apply for chemicals, including SDS requirements:
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In Republika Srpska, the rules for SDS preparation are clearly defined in the Rulebook on the content of the Safety Data Sheet.
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In the Federation of BiH, detailed requirements are still not fully prescribed, so general obligations from the Law on Chemicals apply.
Depending on where your company is based or where you plan to sell chemicals, we will choose the correct document format and ensure compliance with applicable legislation.
The second key question is what input information you have about the chemical. That will determine the best route for preparing the document. There are two most common scenarios:
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Creating an SDS based on the product formulation
If you have a formulation (complete composition of the product) but no SDS yet, we can prepare a brand-new SDS that is fully compliant with the rules of your target market. This is the most common case for chemical manufacturers.
To prepare an SDS from formulation, we need basic product information:
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trade name,
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intended use,
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physical/chemical properties (form, colour, odour, etc.),
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chemical composition.
In this scenario the composition is crucial and must include:
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substance identification (name, CAS number, EC number, REACH number),
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classification of each substance according to CLP/GHS,
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exact concentration (% w/w) of each substance in the mixture.
Based on these data, the mixture is classified and labelled according to relevant rules, and the SDS is created.
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Adapting or updating an existing SDS
Sometimes companies already have an SDS — their own, or a supplier SDS in another language. If that input SDS is not fully aligned with local rules, it must be adapted to the target market. And if the SDS is old, it must be updated.
Even though this scenario looks simpler, full composition data are still necessary. Only with complete data can we reliably verify the classification and ensure compliance.
I have seen cases where a supplier SDS listed only one substance, while the mixture classification clearly showed that hazards must come from additional substances. It also happens that labels (or additional EUH208 statements) list substances that are not included in section 3 of the SDS.
Another common situation: a substance with an occupational exposure limit is listed in section 8, but not in section 3. This usually happens because of differences between local rules and EU rules.
That’s why without detailed composition data, it is not possible to prepare a compliant SDS.
Where to start?
When you need an SDS, first define your target market. Then check what data you have:
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if you have the formulation → we can create a new SDS from scratch,
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if you have a supplier SDS or an older SDS → we can adapt it to current requirements.
Feel free to contact me at nina.pajovic@bens-consulting.eu if you’re unsure what your next step should be. We’ll find the right strategy so you can ensure compliance and protect your customers.
Disclaimer:
The information on this blog is prepared with the greatest possible care, but it does not represent (chemical) consulting. The provider assumes no responsibility or guarantee for the correctness, accuracy or up-to-dateness of the published content. If you need advice for a specific case, you can contact us at nina.pajovic@bens-consulting.eu
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