Bosnia and Herzegovina: Labor Inspector Rejected Our Safety Data Sheets Translations – Is This a Conspiracy?

This is a story many companies – maybe even yours – face when it comes to checking safety data sheets (SDS).

"We have an inspection at the company," said a worried voice over the phone. It was the director of a company.

"The labor inspector rejected our safety data sheets," he continued.

"I'm sure it's a conspiracy because our safety data sheets are perfectly translated."

The key word that set off a light bulb in my head was "translated."

So I asked him how he knew all the safety data sheets were perfectly translated.

The tone changed. With full confidence, the director replied:

"Because a colleague who is a trained translator took care of it and approached the task seriously. There are certainly no mistakes in her work," he said.

My next response surprised him: "I believe she did an excellent job. I also believe she didn't make any translation errors.

However, the inspector wasn't evaluating the quality of your safety data sheet translation. Instead, he compares the information in the document with the original document and the applicable regulations under which SDSs must be prepared.

The translation – whether excellent or poor – is only 10% of a well-prepared safety data sheet.

Regardless of whether you translated them yourself or a translation agency did – such SDSs wouldn't pass an inspection.

I've seen printed safety data sheets whose translations were certified by a court interpreter for a specific language, but they were only good for scrap paper."

At this point, I paused and waited to see if the information had sunk in.

"What do you mean? I don't quite understand," the director continued. My explanation followed.

"As I already mentioned, the adequacy of the document is what matters in a safety data sheet, which must be adapted to national legislation.

The adequacy of the document means that the data listed in it is correct. Specifically, this means whether a hazardous chemical is properly classified according to its composition and listed substances.

Often, the correct H- and P-statements are not listed in the SDS. Or certain P-statements that must be included are missing, such as "Keep out of reach of children."

We notice the most issues in section 8 of the SDS, where personal protective equipment and exposure limit values at the workplace are defined. This section, for example, is reviewed by the labor inspection.

We, as experts, know these regulations, but your colleague doesn't need them and understandably doesn't know them."

I stopped here because I thought I might be going into too much detail.

So I went back to the beginning:

"All the above are crucial pieces of information that your colleague couldn't have known. However, they represent a key obstacle on the path to creating an adequate SDS.

And that's why the labor inspector could reject your safety data sheets as inadequate in just a few minutes."

After a few moments of silence, the voice – this time calm – responded:

"I understand. So, it's not about the negligence of my colleague. And there's no conspiracy by inspectors trying to make our business difficult."

"The inspectors were just doing their job," I replied.

We ended the conversation with his words, "Well, every lesson comes at a cost. I've learned a lot today. How much does it cost for you to prepare safety data sheets, and when can I get them? The inspector has given us a deadline to fix the deficiencies."

If you're diligently translating your chemical documentation — safety data sheets, labels, and maybe even safety instructions — it's time to check if you're on the right track.

I can help you with that. All you need to do is contact me.