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Introduction

In a recent article in Safety and Health Practitioner1, it was stated that “many people have found Safety Data Sheets (SDS) incomprehensible, or even inaccurate”, and various studies2,3 have been carried out on assessment of the accuracy of Safety Data Sheets. In one such study, it was reported that out of 150 SDS, only 37 percent were found to have accurate health effects data and only 47 percent were accurate regarding personal protective equipment or correct occupational exposure limits. 

The introduction of REACH and the implementation of the Globally Harmonised System of Classification and Labelling (GHS) will present greater challenges to the recipients and users of Safety Data Sheets, when they attempt to assess or check the quality of their SDS. In view of the fact that a Safety Data Sheet is a key source of information for employers carrying out workplace risk assessments such as COSHH, it is vital that the SDS must contain accurate and up-to-date data and information. The question is: how can a user determine whether or not a Safety Data Sheet from a supplier or manufacturer is accurate and up-to-date? 


Current Practice

Many employers and Health & Safety Professionals make the assumption that SDS supplied by the manufacturers and suppliers have been generated accurately and therefore negate the need to carry out a check on their accuracies. Some claim that as they are not chemists, therefore they lack the experience and knowledge to conduct such checks. 

When revised SDS are issued by the suppliers, current practice by some SDS users is to conduct basic checks by merely reviewing issue dates and version numbers without making a careful assessment of the revisions. Some take the view that as long as there are revision dates on the SDS, then that ends the quality checks. 

Some employers abdicate their responsibility for checking the SDS by adopting the view that the manufacturers and suppliers would be held accountable if the errors found on the SDS were to lead to serious accidents and/or legal action. This is a wrong assumption to make!

The importance of having quality SDS is emphasised by the HSE as the extract4 from the COSHH Regulations states that “accurate, complete and correct information on data sheets is essential when considering workplace controls, e.g. over-classification of a substance might lead to unnecessarily stringent controls, while under-classification may result in risks to employees’ health. If employers have concerns about the quality and reliability of information provided on a data sheet, or if they are unsure of the application of the information to their situation, they should contact the supplier for clarification or for further guidance”.

Rather than blithely use the information provided by the supplier or manufacturer on a Safety Data Sheet, the employer or recipient should be able to demonstrate that he/she has taken due diligence in checking the quality and accuracy of the SDS prior to using them for COSHH risk assessments.

The Compliance Check (C3) service provided by ESL provides you with a safety net to ensure you can easily, and cost effectively, meet your obligations under the law.  

Results are presented in the form of a clear confidential report confirming compliance or indicating why the Safety Data Sheet does not comply.

Using this service, it is first determined whether the product concerned falls within the scope of the CHIP regulations or the CLP Regulation and, if so, the Safety Data Sheet will be assessed against the PRINCIPAL requirements for compliance as follows:

•  Compliance with REACH Safety Data Sheet format e.g. correct 16 headings and correctly dated
For a substance, whether the classification complies with either that contained in Table 3.1 and Table 3.2 of CLP or the toxicological and ecotoxicological data that are quoted on the Safety Data Sheet.
•  For a mixture, whether the information about the composition complies with CHIP or CLP and, if so, whether the classification has been determined correctly.
•  Whether the substance or substances in a mixture have a reported Occupational Exposure Limit, e.g. WEL in EH40, and, if so, whether it appears correctly on the Safety Data Sheet.
Whether the labelling information is correct.
•  Whether the information in the transport section is consistent with other information provided in the Safety Data Sheet.

Establishing Product Information Quality and Confidence Ratings for Chemical Safety Data Sheets

In the past, searches on SDS revisions have been mainly carried out on the basis of legislative or regulatory changes. There is a need to look at wider aspects and to develop a simple product information quality and confidence rating system for compliance. 

We propose to assign each chemical product with a Confidence Rating Value (CRV). based on the following criteria:

1.  Confidence Rating by SDS Writing Standards
2. Confidence Rating by Information Sources
3.  Confidence Rating by Date
4.  Confidence Rating by SDS Data
       Table 1.  Confidence Rating Values (CRV)  
CRITERIA CRV
Confidence Rating by SDS Writing Standards  
REACH Registered 1
Classification Labelling & Packaging (CLP) 2
Globally Harmonised System (GHS) 3
Chemicals Hazards Information & Packaging (CHIP 4) 4
Chemicals Hazards Information & Packaging (CHIP 3, 2, 1)  5
   
Confidence Rating by Information Sources  
European Chemical Bureau (ECB) database 6
National databases 7
National Inst. Occupational Safety Health (NIOSH) or non-EU 8
   
Confidence Rating by Date  
SDS Review and/or Issue Date (more than 10 years)* 9
   
Confidence Rating by SDS Data  
SDS data from unverifiable sources  10
 * Writing Date (not printing date)  

Therefore, Confidence Rating Value (CRV) of 1 would indicate highest confidence whilst CRV of 10 would give the lowest confidence rating.

Table 1 shows a simple SDS Information Quality and Confidence Rating system that would allow recipients and users of Safety Data Sheets to quickly assess the CR Values of the SDS they currently use. For example, consider the information that might be shown for popular Petroleum based crude solvent such as “Mineral Spirit”. An old Safety Data Sheet (i.e. CRV of 10) would not always indicate a Carcinogen Category 2 whereas an accurate SDS that is REACH Registered (i.e. CRV of 1) would indicate a more refined product without the Benzene component. This SDS is up-to-date, more accurate and would be a preferred one to use for COSHH assessments.

The CRV system is based on an effective working practice by Environmental Science Limited and by the extension of the procedure, it could be used to establish product information quality and confidence ratings for recipients and users of Safety Data Sheets to quickly appraise where a SDS should be updated or re-written. An example showing the principle of how the CRV system could be developed into a spreadsheet is shown in Table 2.

Conclusion

A simple SDS check system at a glance is proposed. This can be achieved by adopting the principle of Confidence Rating Value (CRV) system. For in-depth technical assessment of Safety Data Sheets, it is recommended that users of SDS seek the advice of a specialist.


References:

1.  Substantial makeover – Mark Blainey, SHP June 2010.
2.  Assessment of the Accuracy of Material Safety Data Sheets – Kolp, Williams & Burtan, 1995 Journal of American Industrial Hygiene Association, Volume 56, Issue 2, pp 178-183.
3.  A report on Inaccuracies in Safety Data Sheets, HSE’s 3Rs programme, PD/7/1, 18 November 1999.
4.  The Control of Substances Hazardous to Health Regulations 2002 (as amended), Approved Code of Practice and Guidance L5 (5th edition), HSE Books 2005.
5.  CHIP Compliance Check (C3) Service Environmental Science Limited, 1999.
6.  Workplace Exposure Limits, Health and Safety Executive, EH40/2005 (as updated and amended)
 

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