Is it Time to Revise Your Safety Data Sheets?
Safety Data Sheets (SDSs) should be periodically reviewed and revised as necessary. Every country/ jurisdiction provides guidance on when a safety data sheet should be updated and very few specify a timeline for periodic review. Most jurisdictions are in general agreement that a review or update is necessary as new information becomes available that could impact the accuracy of and protection provided by the SDS.
Guidance is vague on what constitutes new information and what type of information would trigger an update. From a regulatory standpoint, the following changes should automatically trigger SDS review and updates as necessary:
- Composition Change: A change in composition may result in a change in the hazard classification of a product.
- New Hazard Classification: The hazard classification of a substance is subject to change as new data becomes available. Such changes can impact the hazard classification of a product.
- Regulatory List Status: If a substance is added to or removed from certain regulatory lists, the SDS for any product containing that substance should be updated.
- A substance is added to the EU REACH restriction list.
- A substance is added to the US TSCA Section 5 SNUR (Significant New Use Rule) list.
- New Jurisdiction Standard Released/Alignment with Later GHS Revision: A new jurisdictional standard may have additional hazard classes and concentration limits to trigger the classification of a mixture. This may result in a change in hazard classification. Changes to precautionary statements, format, and data requirements are common with the adoption of later GHS revisions.
- Occupational Exposure Limits: New or modified occupational exposure limits or biological exposure indices for a substance should prompt the update of any SDS containing that substance.
A few jurisdictions have established a mandatory schedule for SDS review. For jurisdictions without a timeline, periodic review is still extremely important to ensure the accuracy and compliance of the document. It is good practice to establish a definite SOP for this purpose.
The conditions that warrant safety data sheet review and the deadline for providing updated SDSs are outlined below for the United States, Canada, EU, Japan, China, and Australia.
Chemical manufacturers, importers, distributors, or employers who become newly aware of the following shall revise SDSs within 3 months and labels shall be revised within 6 months:
- Any significant information regarding the hazards of a chemical,
- Ways to protect against the hazards
OSHA does not require periodic SDS review.
Suppliers are required to update SDSs within 90 days when
- The supplier becomes aware of any “significant new data” that changes how the hazardous product is classified.
- There are changes to the way the product is handled or stored.
WHMIS does not require periodic SDS review.
REACH requires suppliers to update the safety data sheet without delay on the following occasions:
- As soon as new information, which may affect the risk management measures, or new information on hazards becomes available (i.e. new classification).
- Once an authorization has been granted or refused.
- Once a restriction has been imposed.
- Any updates following registration shall include the registration number.
REACH does not require periodic SDS review.
Manufacturers are required to revise SDSs every 5 years.
A supplier is required to update a safety data sheet without delay and provide revised edition to recipients if the supplier becomes aware of any new information concerning a chemical.
Japan does not require a periodic SDS review.
The manufacturer or importer of the hazardous chemical must amend the SDS whenever necessary, to ensure that it contains accurate information. For example, if new data becomes available which changes the chemical’s hazard classification.
SDSs must be review at least once every 5 years.
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