Safety Data Sheet in Practice: When, Who, and for Which Chemicals is it Required?

Safety Data Sheet (SDS) is a key document for every chemical.

It contains crucial information for safe handling, storage, and disposal of chemicals, and serves as a basis for preparing workplace safety measures and implementing legislative requirements.

In practice, questions often arise about which chemicals require a safety data sheet and to whom and when it must be provided.

Which chemicals require a safety data sheet?

According to the REACH Regulation, a safety data sheet must be provided for:

• chemicals (substances or mixtures) that are classified as hazardous,
• substances that are persistent, bioaccumulative, and toxic (PBT) or very persistent and very bioaccumulative (vPvB),
• substances listed as candidates for Substances of Very High Concern (SVHC).

Is a safety data sheet required for non-hazardous chemicals?

Even if a chemical is not classified as hazardous, a safety data sheet must be provided upon request by the recipient in the following cases:

• if the mixture contains hazardous substances above prescribed concentrations (usually above 1% or 0.2% for certain hazard classes, including PBT, vPvB, and SVHC substances),
• if it contains substances with established occupational exposure limits (at the community level).

This means that the fact that a chemical is not classified as hazardous does not mean a safety data sheet is unnecessary. The criteria mentioned above must still be checked.

What about products for general use?

For chemicals intended for general use, legislation usually requires that sufficient information for safe use is already on the product label. Therefore, a safety data sheet does not need to be provided to the general end-user.

Companies, legal entities, and sole proprietors need safety data sheets even for products for general use, as only with a safety data sheet can they meet all legislative requirements (e.g., reporting in ISK for Slovenia, workplace safety requirements, transport of dangerous goods, etc.).

Supplier and importer obligations

The obligation to provide a safety data sheet applies to both suppliers and importers and distributors of chemicals.

Generally, EU suppliers must provide safety data sheets in the appropriate languages to all their customers (companies), who are importers or distributors. If not, this obligation shifts to the importers and distributors.

How should the safety data sheet be delivered?

The safety data sheet must be:

• available free of charge,
• provided in written or electronic form,
• prepared in the appropriate language of the country where the product is marketed.

It is important to emphasize that it is not sufficient for the document to be merely published on the company's website. It must be directly sent to the recipient or provided with a link where it can be downloaded.

Employee access to safety data sheets

If employees use chemicals in their work, the employer must ensure access to safety data sheets. This way, employees are informed about the hazards and protective measures when working with chemicals.

Updating safety data sheets

In certain cases, the safety data sheet must be updated and the new version provided to both existing and new customers. This is especially true when there are changes in classification, composition, or regulatory requirements.

Conclusion

The obligation to provide a safety data sheet depends on the classification and composition of the chemical.

Most importantly, the safety data sheet must be up-to-date, understandable to the user, and prepared in accordance with current legislation.

If you need assistance in preparing safety data sheets, we can help you.