All about Safety Data Sheets

Hazardous substances are those that can cause harm to human health and/or the environment. Some are also classified as dangerous substances, as they can cause fire, explosions and uncontrolled reactions.

According to the HSE, every year, thousands of workers suffer from ill health because of exposure to hazardous substances. These diseases are a cost to industries, individuals and society. In fact, the HSE estimate that the costs run into millions of pounds every year.

Hazardous substances are present in most, if not all, workplaces. Some are produced by certain work activities or processes, e.g. welding fume; others are biological, such as viruses and bacteria.

The hazardous substances more commonly used at work are chemicals that have a wide range of uses for specific work activities, e.g. cleaning chemicals, inks, paints, solvents, adhesives, fuels, pesticides, biocides, etc. Hazardous substances also include preparations and mixtures of substances.

By law, chemical suppliers must provide information on any of their substances classified as hazardous. You can find this information on labels and safety data sheets (SDS). For example, if you buy hazardous paint, there must be a hazard pictogram on the label or packaging, and the product must come with an SDS.

SDS contain vital information on chemicals that can help employers identify the hazards associated with hazardous substances and assess the risks to employees and others, which is a legal requirement under the COSHH Regulations.

This article will look at what safety data sheets are and the information they contain. It will also cover the laws surrounding these documents, how to obtain them and what to do with SDS once they are on-site.

What are safety data sheets?

The HSE defines safety data sheets (SDS) as:

“Important documents in the safe supply, handling and use of chemicals.”

SDS:

• Contain important information about a hazardous substance, e.g. properties, hazards, health and environmental effects, exposure limits, handling, storage, emergency measures and PPE.
• Are required to complete a COSHH assessment (as per the requirements of the Control of Substances Hazardous to Health Regulations 2002 (COSHH)).
• Assist in the safe use of chemicals to prevent risks to people and the environment.
• Do not constitute a risk assessment because the information relates to the substance, not its use in the workplace.

You may come across the terms Material Safety Data Sheets (MSDS) or Product Safety Data Sheets (PSDS), but these are considered dated. Safety data sheets (SDS) is now the term widely used.

What information is in safety data sheets?

When you first look at an SDS, it can appear quite complex. There are a lot of technical terms and data. However, once you break down the SDS and look at each section, it can be understood by those with some knowledge of hazards and chemicals.

There are typically 16 sections in an SDS, which are:

1. Identification of the substance or mixture (e.g. chemical name/trade name), details of manufacturer/supplier and emergency contacts.

2. Identification of hazards associated with the substance, e.g. classification and label.

3. Hazardous substance ingredients/composition.

4. First aid, e.g. symptoms and what to do in the event of eye/skin contact, inhalation and ingestion.

5. Firefighting, e.g. what extinguishers to use and what not to use.

6. Accidental release, e.g. what to do in the event of a spillage.

7. Handling and storage of the substance, e.g. incompatibility, safe storage and hygiene measures.

8. Exposure/Personal Protective Equipment (PPE), e.g. any workplace exposure limits and personal protective equipment suggestions.

9. Properties of the substance (physical and chemical), e.g. substance form (liquid/gas), flash points and boiling points.

10. Stability and reactivity, e.g. conditions to avoid.

11. Information on toxicology, e.g. what tests have been done (i.e. animal testing).

12. Ecological information, e.g. ecological toxicity.

13. Disposal of the substance, e.g. how to dispose of the substance, empty packaging and contaminated packaging.

14. Transport of the substance, e.g. UN Number, hazard class and environmental hazards.

15. Regulatory information, e.g. applicable legislation.

16. Other information, e.g. revision date.

SDS, in addition to labels, are important in identifying hazardous substances in the workplace. They contain detailed information that is fundamental when producing COSHH assessments.

What is the main law on safety data sheets?

SDS are a legal requirement under the UK REACH Regulation, which has been retained in UK law since leaving the EU. The regulations cover the registration, evaluation, authorisation and restriction of chemicals (REACH).

By law, chemical suppliers must provide an up-to-date SDS if:

• A substance or mixture is classified as hazardous under the CLP Regulation and supplied for work use (whether packaged or not).
• Chemicals are not classed as hazardous but still contain small amounts of hazardous substances.
• Substances meet the criteria as persistent, bio-accumulative and toxic (PBT) or very persistent, very bio-accumulative (vPvB) to the environment in accordance with REACH.
• Substances which appear on the UK REACH Candidate List of substances of very high concern (SVHCs) for authorisation.

Are there any other laws relating to safety data sheets?

Other laws that apply to SDS are:

• The Health and Safety at Work, etc. Act 1974 (section 6)
  – Designers, manufacturers, suppliers and importers have legal duties under HSWA (section 6). This section of the Act refers to substances.
  – Duty holders must ensure that substances are:
  Safe and without risks to health at all times when it is being used, handled, processed, stored or transported by a person at work or on the premises, so far as is reasonably practicable.
  Tested and examined as necessary.
  Supplied with adequate information, e.g. an SDS.
  Supplied with revisions of information, if necessary.
• The Control of Substances Hazardous to Health (COSHH) Regulations 2002 (as amended).
  – The COSHH Regulations place duties on employers to reduce the risks to health by preventing or adequately controlling exposure to hazardous substances.
  – Regulation 6 of the COSHH Regulations requires employers to assess the risks of hazardous substances to employees and others before work, known as a COSHH assessment.
  – The COSHH Regulations state that a COSHH assessment should consider: “Information on health effects provided by the supplier, including information contained in any relevant safety data sheet”.
  – Employers should use the information within an SDS to help them complete their COSHH assessment.
• The Classification, Labelling and Packaging (CLP) Regulation
  – Covers the classification, labelling and packaging of substances and mixtures.
  – Since Brexit, the EU CLP Regulation (as amended) has been retained in GB law and is now known as the GB CLP Regulation.
  – GB CLP applies to GB-based manufacturers, importers, downstream users and distributors supplying the GB market. Companies supplying to the EU market must also adopt EU CLP.
  – GB CLP requires duty holders to classify, label and package substances and mixtures in accordance with the regulation.
  – CLP adopts the United Nations’ Globally Harmonised System (GHS) for the classification and labelling of chemicals.
  – The information within an SDS comes from the classification of substances and mixtures.

Are safety data sheets COSHH assessments?

No, an SDS is not a COSHH assessment.

A COSHH assessment requires an assessor to look at the information provided by the chemical supplier in the SDS and make a specific assessment covering some of the following points:

• The hazards and substance forms, e.g. gas, vapour or fume.
• What the substance will be used for.
• Where the substance will be used.
• How the substance will be used, i.e. the method.
• The quantity used.
• The frequency of use.
• Who will use the substance.

A company will be breaking the law if they only keep a collection of SDS, as they do not constitute an actual assessment of the risks. They must ensure they complete a risk assessment specific to the use of the chemicals on-site.

How to obtain safety data sheets

Chemical suppliers must:

• Ensure SDS are prepared by a competent person.
• Ensure the SDS is specific to the chemical supplied.
• Supply an SDS (in electronic or paper form) free of charge the first time they provide a substance (before or at the time of delivery).
• Ensure the SDS is in the correct language and is clear and understandable.
• Keep SDS up to date, revised and reissued as necessary.

It is important to note that chemical suppliers cannot rely on a system where chemical users only have access to SDS via a company’s website or a catalogue of SDS. Chemical users must be given a copy of the SDS before or on delivery. For re-orders, chemical suppliers do not need to send an SDS unless they have reviewed the document.

If a manufacturer or supplier fails to provide an SDS with their products, they will be breaking the law.

Chemical users can also obtain SDS in the following ways:

• Contacting the manufacturer or supplier directly and asking them for a copy.
• Looking online, as some companies have a library of SDS on their websites.
• On online safety data sheet databases.

What to do once safety data sheets are obtained

Check the SDS on receipt of chemicals

Whoever is receiving deliveries of chemicals should check the following:

• They have the correct SDS for the chemicals provided by checking the label against the SDS (section 2) and ensuring it is the current version.
• The SDS has 16 sections and is dated.
• The SDS is clear, concise and in English.

If there are any issues with the SDS, the responsible person should contact the supplier or manufacturer for advice or an updated copy of the SDS.

Complete a COSHH assessment

Employers should use the information in the SDS to complete their COSHH assessments, and they can use the HSE’s COSHH e-tool to help them. Once they have completed the COSHH assessments, they must inform employees of the hazards and control measures, including what to do in an emergency.

Store SDS

Copies of SDS should be kept (hard copy or electronic) in a known location readily accessible to all employees.

It is advisable for employers to keep a chemical inventory that lists all chemicals and the version numbers and dates of SDS and COSHH assessments.

The COSHH Regulations allow employees access to any relevant SDS. Therefore, employers must make SDS and COSHH assessments available to employees and their representatives under the information, instruction and training requirement in the COSHH Regulations.

Review SDS and COSHH assessments

Employers must review SDS regularly to ensure that the information has not changed. Some manufacturers change the composition of their chemicals, and the hazards and controls can change. A more hazardous substance can become less hazardous and vice versa.

If the SDS has changed, this will also mean employers will need to review their COSHH assessments to ensure their control measures are still valid.

Summary

The information contained within an SDS is crucial, and it will be difficult for employers to complete a COSHH assessment without this document. Hence, why the COSHH Regulations require employers to consider the information within SDS when assessing the risks of hazardous substances.

Chemical suppliers have a legal duty to provide SDS under UK REACH. Once chemical suppliers have fulfilled their legal duties, the onus is then on the employer to confirm they have the correct SDS for the chemicals and substances they have on-site. They must also ensure their COSHH assessments comply with the COSHH Regulations.

Hazardous substances can cause harm to people, animals and the environment. The effects can be wide-ranging and depend on the type of substance, its form and its hazardous nature. Therefore, using the information within an SDS and properly assessing hazardous substances can reduce the risk of accidents, incidents and ill health in and out of the workplace.

Why not take our ROSPA-approved COSHH awareness course to learn more about hazardous substances?