The American and European safety data sheets differ – what now?

Basically, all information, regardless of the origin of the safety data sheet (SDS), is provided in the document in accordance with local legislation.

The format or manner in which this information is presented can vary depending on the geographical origin.

In other words, the content and format of the SDS are precisely prescribed by the legislation applicable to that region. For example, in Europe, the format of the SDS is determined by REACH Regulation 1907/2006, while in America, it is governed by the OSHA Hazard Communication Standard (29 CFR 1910.1200).

The sequence, naming, and numbering of sections and subsections that must be used in the SDS are thus legally defined and can vary by country.

Differences can also arise in content, as, for example, different criteria for chemical classification apply in America compared to Europe.

How does this manifest in practice?

A company provided us with an original American SDS with the request to translate it into Slovenian. We did not translate the SDS literally; instead, we adhered to EU legislation, which dictates the content and format of SDS in the EU. The American SDS, therefore, differed in format and content from the European one that we produced.

The client noticed this when comparing the European SDS with the original American one and complained.

This led to our explanation of why the European SDS differs in section 2 from the original American one.

What does it mean if the original American SDS were simply translated literally?