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The Regulation on Reporting Chemical Data clearly distinguishes between two types of changes:
- Immediate update is required when the product's trade name changes or when the change increases the chemical's health hazard. In these cases, there is no time to delay.
- Annual update is sufficient for other changes to the safety data sheet. These must be reported to ISK by March 31 for the previous year.
Common mistake: companies often postpone even minor changes "until next year" and then forget about them amidst other tasks.
How to Approach Reviewing ISK Submissions?
A good start is to export data from the ISK system into an Excel table. This overview quickly reveals which submissions are outdated and likely need updating.
A detailed review requires:
- comparing each ISK submission with the current safety data sheet,
- checking if any changes in composition, classification, or labeling have been reported, verifying
- whether there are still active submissions in the system for chemicals the company no longer markets.
This last point is often overlooked: de-registering a chemical that is no longer on the market is also part of ISK maintenance.
In Conclusion: ISK is a Tool, Not a Formality
Companies that regularly update their ISK submissions find themselves in a completely different position during an inspection than those that do not. This is not about luck. It's about a system that works.
If you're unsure about the status of your ISK submissions or would like a systematic review before the next inspection, we at BENS Consulting are here to help.
Email me at simona.miklavcic@bens-consulting.eu. Together, we can assess the current situation and prepare an action plan.
bojan.dimic@bens-consulting.eu
