A safety data sheet is not just a mandatory attachment to a chemical

Under the European REACH Regulation, a safety data sheet is intended to enable the user to take the measures necessary to protect employees' health, occupational safety and the environment.

For an employer, it is therefore above all a source of information for risk management.

Do you need a new sheet or a revision of your documentation? You will find an offer and the required inputs on the page Preparation and revision of safety data sheets.

If a company uses, for example, a two-component adhesive, it is not enough to have the safety data sheets of both components saved on a computer. You need to find out from them whether the mixture contains sensitising substances, what the ventilation requirements are, which gloves the manufacturer recommends, whether an exposure limit exists, and what is to be done in the event of a spill.

The same rule applies to a paint shop, a welding shop, a laboratory, maintenance and ordinary production.

In practice: A safety data sheet should answer the question "what must we do differently in our operation with this chemical?" If the company has derived no practical measure from it, it is very likely being used only as a formality.

When a safety data sheet must be available

The basic rules are set out in Article 31 of the REACH Regulation.

A safety data sheet is provided in particular for substances and mixtures classified as hazardous under the CLP Regulation.

Under certain conditions, a safety data sheet may also be provided on request for a mixture that is not itself classified as hazardous but contains certain hazardous substances, substances with an exposure limit or other substances listed in REACH.

It is therefore not the right approach to decide solely on the basis of whether hazard pictograms appear on the packaging.

If the supplier has not sent a safety data sheet and the company has reason to believe that it needs one for the product, it is advisable to request it from the supplier.

In the Czech Republic you need a Czech version

REACH provides that the safety data sheet must be supplied in the official language of the Member State in which the substance or mixture is placed on the market, unless that State provides otherwise.

For ordinary operations in the Czech Republic, you therefore need a safety data sheet in Czech.

An English or German version may be useful as a supplementary document, but it should not replace the Czech safety data sheet for a product supplied to the Czech market.

This is particularly important when buying chemicals from abroad or over the internet.

If a foreign supplier sends you only an English document, it is advisable to resolve the question of the Czech version at the time of purchase, not only during an inspection.

How to tell that a safety data sheet is not out of date

On the first page of the safety data sheet, look for the date of issue or revision and the version number.

The current requirements for the structure and content of safety data sheets are based on Annex II to REACH as amended by Commission Regulation (EU) 2020/878.

The transitional period for using older safety data sheets ended on 31 December 2022.

That does not mean, however, that every safety data sheet must be reissued every year.

What matters is whether it is up to date with regard to the classification of the product, its composition and the requirements in force.

The supplier must update the safety data sheet in particular where new information becomes available that may affect risk management measures or hazard information, or where other situations laid down in REACH arise.

In practice: An older date alone does not automatically mean that a safety data sheet is invalid. It is suspicious, however, if a company has used the same product for several years, the supplier has meanwhile issued a new version, and the old document is still in use in operations.

A safety data sheet has 16 sections – not all are equally important for operations

A safety data sheet has a prescribed structure of 16 sections.

For an ordinary operator, sections 1, 2, 3, 4, 5, 6, 7, 8, 10, 13, 14 and 15 are of the greatest practical importance.

It is not necessary for every employee to study the whole twenty-page document. The company must, however, be able to turn the important information into simple operating rules.

Section 1: Are we really using the product the sheet belongs to?

The first section contains the identification of the substance or mixture, recommended uses, supplier details and emergency contacts.

It sounds obvious, but this is exactly where one of the common mistakes arises.

A product with one trade name is in the warehouse, and the company presents the safety data sheet of a similar product from the same manufacturer.

That is not enough.

The safety data sheet must correspond to the specific product being used.

Check therefore the trade name, the manufacturer and, where applicable, the product code.

Section 2: What is hazardous about the product

Section 2 is one of the most important.

It contains the classification of the substance or mixture under CLP, label elements and other hazard information.

This is where you find out whether the product is, for example:

  • flammable,
  • corrosive,
  • acutely toxic,
  • sensitising,
  • carcinogenic,
  • mutagenic,
  • toxic for reproduction,
  • hazardous to the aquatic environment.

Many further obligations follow from this classification.

You will deal with the storage of an ordinary detergent differently from a chemical with acute toxicity category 1 or 2.

Section 2 should also be consistent with the labelling of the product on the packaging.

If the label and the safety data sheet state different classifications, the situation needs to be clarified with the supplier.

Section 3: What the product actually contains

Section 3 contains information on composition.

For mixtures, it usually does not list absolutely all the components, but the substances that must be declared in the safety data sheet under the REACH rules.

This section is very important for an occupational hygienist or a laboratory.

If, for example, employees use a cleaning product, a varnish, a hardener or an adhesive, the composition is what allows a preliminary determination of which chemical substances may be relevant for the assessment of workplace air.

It is not always possible, however, to blindly measure only the first substance listed in section 3.

You need to take into account its concentration, volatility, method of use, process temperature, quantity of product and duration of exposure.

Sections 4, 5 and 6: What to do when something happens

Section 4 contains first-aid instructions.

Section 5 deals with firefighting measures.

Section 6 deals with measures in the event of accidental release.

This information should be reflected in the emergency preparedness of the operation.

If the safety data sheet requires, for example, that the substance be prevented from entering the sewer, it must be realistically possible to protect the sewer in the event of a spill.

If a certain type of sorbent is recommended for cleaning up a spill, it is advisable to check whether the company actually has it.

If immediate rinsing is required after eye contact, the worker must have a suitable rinsing facility available within a reasonable distance.

In practice: Emergency measures are not fulfilled by the procedure being written in the safety data sheet. Physical means must also exist with which it can actually be carried out in operations.

Section 7: How to use and store the substance

Section 7 deals with handling and storage.

For the operator, this is one of the key sections.

It may state a requirement for ventilation, protection from heat, storage away from ignition sources, protection against moisture or segregation from incompatible substances.

This information should correspond to the actual storage area.

If the safety data sheet requires, for example, storage in a cool and well-ventilated place, it is not appropriate to place the whole stock next to a process furnace.

If a substance must not come into contact with oxidising agents, they should not be placed together in one containment tray.

We also looked at the storage issue in more detail in our article on the storage of chemical substances and mixtures.

Section 8: One of the most important sections for employers

Section 8 contains information on exposure controls and personal protective equipment.

It typically states, for example, exposure limits and requirements for technical measures and for protection of the eyes, hands, respiratory tract or body.

Information about gloves is very important.

The safety data sheet may specify a particular glove material, for example nitrile, butyl rubber or another material, and sometimes also the required breakthrough time or thickness.

It is therefore not enough simply to issue an employee with "rubber gloves".

The glove material must be suitable for the specific chemical substance.

Likewise, information about a respirator does not automatically mean that inadequate extraction can be compensated for by the permanent use of respiratory protection.

Under the principles of occupational health protection, technical and organisational measures are to take priority.

A safety data sheet is a basis for health risk assessment

This is where the safety data sheet is directly linked to the work environment.

The current Government Decree No. 361/2007 Coll. expressly provides that the health risk assessment of an employee exposed to a chemical substance or mixture includes the use of data from the safety data sheet and other sources relating to chemical safety.

The employer therefore should not merely know which products it has purchased.

It must find out:

  • which substances employees may be exposed to,
  • during which work operations,
  • how long the exposure lasts,
  • how the substance enters the body,
  • whether an exposure limit exists,
  • what measures have already been introduced,
  • whether the exposure needs to be objectively verified by measurement.

This is essential, for example, in painting, bonding, degreasing, PUR production, laboratories, chemical production or the application of resins.

A safety data sheet alone does not decide what you should measure

A common misconception is to send a laboratory ten safety data sheets and expect it to automatically measure all the substances listed in the composition.

Such an approach can be very expensive and at the same time technically wrong.

First it is necessary to know the work process.

Decisive factors include, for example:

  • the quantity of product used,
  • open or closed application,
  • process temperature,
  • manual or automatic dosing,
  • working time,
  • extraction efficiency,
  • the physical properties of the substance,
  • the number of exposed workers.

Only by combining the technology and the safety data sheets can a suitable scope of measurement be determined.

For example, a high content of a substance in a liquid product does not yet mean a high concentration in workplace air. Conversely, even a smaller quantity of a very volatile or highly hazardous substance may be important.

Beware of substances that act through the skin

With chemical agents, we often concentrate only on inhalation.

That can be a mistake.

Some chemical substances can also be absorbed significantly through the skin or mucous membranes.

Government Decree No. 361/2007 Coll. therefore requires all routes of exposure to be taken into account in the health risk assessment.

In such a case, it is not enough to say that the concentration in the air was low.

The method of handling, contamination of the hands, unsuitable gloves or contact with contaminated surfaces may be important.

Section 8 of the safety data sheet helps determine suitable protective measures.

Carcinogens, mutagens and substances toxic for reproduction require special attention

If the safety data sheet shows that a product contains a carcinogenic, mutagenic or reproductive toxic substance, the situation may be considerably more serious than with an ordinary hazardous chemical mixture.

Further requirements may then apply at the workplace for risk assessment, minimisation of exposure, technical measures, a controlled area, records or occupational health supervision.

The basic principle is to consider replacing the hazardous substance with a less hazardous alternative, where this is technically possible.

We therefore recommend not overlooking these classifications when checking safety data sheets.

A safety data sheet must match the way the product is used

Section 1.2 of the safety data sheet lists the relevant identified uses and, where applicable, uses that the supplier advises against.

This is important, for example, when a company uses a product in a different way from that for which it was normally supplied.

A typical example is a switch from manual application to spraying.

Spraying may produce a markedly different exposure from application by brush or roller.

If the actual use is not covered by the supplier's information or by an attached exposure scenario, the situation needs to be addressed further.

What exposure scenarios are

For some registered substances, an exposure scenario may be attached to the safety data sheet.

It describes the conditions of use and the risk management measures under which the substance can be used safely.

For the downstream user, it is important to verify whether the actual manner of use corresponds to the conditions of the scenario.

Not every safety data sheet must, however, have an exposure scenario.

If it forms part of the documentation, it should not simply be ignored during an internal check as an "annex that nobody reads".

Employees must have access to the information

Article 35 of REACH provides that employees and their representatives must have access to information on the substances or mixtures that they use at work or to which they may be exposed.

This does not mean that every worker must read the entire safety data sheet before a shift.

They must, however, be given the information in a form that is genuinely usable for their work.

In practice, this may mean, for example:

  • a work instruction,
  • training,
  • an overview of the main risks,
  • rules for PPE,
  • the procedure in the event of a spill,
  • first-aid instructions.

The safety data sheet thus serves as an expert source from which the company creates clear operating information for employees.

The safety data sheet and the label have to meet

During an inspection, it is very useful to take a specific pack of the product and place the safety data sheet next to it.

Check whether the following match:

  • product name,
  • supplier,
  • hazard pictograms,
  • signal word,
  • basic classification,
  • H statements.

If the packaging states, for example, a new classification and the company has a safety data sheet with the old classification, it is very likely that the documentation is not up to date.

Similarly, it is a problem if the original label is damaged or illegible.

What to do with chemicals decanted into working containers

In operations, part of a chemical is commonly decanted from the original packaging into a smaller working container.

This is where many mix-ups arise.

A container with a handwritten label such as "cleaner", "thinner" or "oil" may not give the employee enough information.

The method of labelling must suit the specific situation, but the basic aim is always to prevent mix-ups and to ensure that the employee knows what they are working with and what risks the substance presents.

Chemical products should never be stored in beverage bottles or other containers that may lead to confusion about their contents.

A safety data sheet and waste are not the same thing

Section 13 of the safety data sheet contains information on the disposal of the substance or mixture.

It does not, however, automatically determine the waste catalogue number.

Waste is classified under the Waste Act and according to the actual origin and properties of the waste.

The safety data sheet is an important basis for this decision, but it is not the only criterion.

This is particularly important for residues of paints, solvents, adhesives, contaminated sorbents, packaging and process sludges.

Section 14 helps with transport, but does not cover the whole warehouse

Section 14 contains information on the transport of dangerous goods.

It may state, for example, the UN number, proper shipping name, hazard class or packing group.

This information is important in particular for transport under ADR.

It is not correct, however, to use the ADR classification as a substitute for classification under CLP or as the sole basis for storage.

These are different legal systems and they address different risks.

Section 15: legislation and restrictions

Section 15 contains information on safety, health and environmental regulations specific to the substance or mixture.

It may draw attention, for example, to certain restrictions under REACH.

If a specific restriction is stated there, it is advisable to verify whether the way the product is used in the company meets its conditions.

A typical example is diisocyanates, for which REACH lays down, under certain conditions, mandatory training for professional and industrial users.

The safety data sheet can thus draw attention to an obligation that is not obvious at first glance from the product label.

What a company should do when a safety data sheet changes

It is not advisable simply to overwrite the old file with the new version of a safety data sheet.

First find out what has changed.

Information about the revision is usually given in section 16 or marked directly in the document.

If only the supplier's address has changed, the impact on operations will be minimal.

If, however, the classification of the product, the PPE requirements, the exposure limit or the storage conditions have changed, the following must also be checked:

  • the risk assessment,
  • storage,
  • the work procedure,
  • PPE,
  • employee training,
  • job categorisation,
  • where applicable, the scope of workplace air measurement.

That is the real purpose of updating a safety data sheet.

The most common mistakes in practice

A very common problem is a folder containing hundreds of safety data sheets among which nobody can tell any more which products are actually in use.

Another mistake is duplicates and several different versions of one document without any indication of which version is current.

We also encounter safety data sheets in a foreign language, documents for a different product, or safety data sheets that no longer match the label on the packaging.

A more serious problem arises when the company has the correct safety data sheet but has not carried the information from it into operations.

The manufacturer requires local exhaust ventilation, but work is carried out without it. It recommends a specific glove material, but employees use others. The product is not to be stored with oxidising substances, but in the warehouse it stands right next to them.

In such a situation, the mere existence of a safety data sheet is of little help to the company.

A simple system that works

Most companies do not need a complex information system.

We recommend keeping one up-to-date list of the chemical products in use.

Each product should have the following assigned to it:

  • the current safety data sheet,
  • the place of use,
  • the place of storage,
  • the maximum quantity used or stored,
  • the job positions that work with the product.

When a new chemical product is introduced, someone should check the safety data sheet before its first use and assess whether it requires a change to storage, extraction, PPE, training or the assessment of the work environment.

It is equally important to remove from the system products that are no longer used and to deal with their physical disposal.

What you can send us for assessment

If you are not sure whether your safety data sheets and chemical documentation are set up correctly, send us a list of the chemical products you use and their current safety data sheets.

For production operations, it is advisable to add also a brief description of the technology, the work operations, the consumption of individual products, the number of exposed workers and information on ventilation or local extraction.

From these inputs, we can check whether the safety data sheets correspond to the products in use, which substances are significant from the work environment point of view, and whether the documentation gives rise to further requirements for storage, PPE, training or the measurement of chemical substances in workplace air.

The aim is not to create yet another folder of documentation. The aim is to carry the information from the safety data sheets into real operations.

You will find more information on the page Chemical substances in operations – NATURCHEM.

Brief summary

A safety data sheet is not just a document from the supplier. It is one of the basic inputs for assessing chemical risks at the workplace.

A company should have a current safety data sheet for the product actually used and, in the Czech Republic, as standard in Czech.

The most important thing is to carry the information from the safety data sheet into practice: store the chemical correctly, ensure suitable extraction and ventilation, choose appropriate personal protective equipment, prepare measures for an accident and assess employees' exposure.

Special attention should be paid to sections 2, 3, 7 and 8, because it is from them that the most important risks, storage conditions, composition and worker protection requirements can often be identified.

The most common mistake is not that the safety data sheet is missing altogether. More often the company has it, but the actual way of working does not meet its requirements.

Factual basis of the article

The basic rules for safety data sheets are laid down in Regulation (EC) No 1907/2006 of the European Parliament and of the Council – REACH, in particular Articles 31 to 36.

Article 31 lays down the conditions for providing a safety data sheet and its basic requirements. Article 35 governs the access of employees and their representatives to information on the substances and mixtures that they use or to which they may be exposed at work.

The requirements for the current structure and content of safety data sheets are laid down in Annex II to REACH as amended by Commission Regulation (EU) 2020/878.

The rules for the classification, labelling and packaging of hazardous chemical substances and mixtures are laid down in Regulation (EC) No 1272/2008 – CLP.

The requirements for health risk assessment when working with chemical substances and mixtures, exposure limits and workplace measures are laid down in Government Decree No. 361/2007 Coll.. This decree expressly requires data from safety data sheets to be used in the health risk assessment.

Further Czech requirements for handling hazardous chemical substances and mixtures are contained in Act No. 258/2000 Coll., on the Protection of Public Health, in particular Section 44a.