Are you a formulator of chemical products, such as paints or detergents? Or do you use chemicals industrially or professionally, for example in your chemical laboratory, automobile repair shop or pool cleaning business? Chances are that the Safety Data Sheets (SDSs) accompanying the chemicals you purchase do not always meet the regulatory requirements. As a downstream user (DU), you may have experienced that this can severely complicate your organisation’s efforts to reach regulatory compliance.

Statistics show you are not the only one in this situation

In 2014-15, the Dutch Workplace Inspectorate (ISZW) conducted a survey among downstream SMEs regarding the use of solvents. The results indicated that:

• More than 75% of the SDSs examined contained poor-quality data (e.g. lacking or including incorrect toxicological information, CLP classifications, risk management measures (RMMs) and/or personal protection measures (PPM));
• 25-50% of the downstream users (DUs) did not have an SDS or have one that was outdated;
• 75% of the companies had not performed a risk assessment, registration or RMMs.

Evidently, many DUs lack safety data sheets (SDSs) for the chemicals they use, while most of the SDSs that were provided by upstream suppliers fall short in terms of quality. Indeed, we recieve many requests from DUs which are in one or more of the situations described above.

What we can do for you

As a DU, you must identify and apply the appropriate measures to control risks associated with the use of chemicals. This applies to your internal processes, and, if you place products on the market, also to the activities of your customers.

If the information on your supplier’s SDS is lacking, you must contact your supplier. However, identifying whether an SDS is truly non-compliant may be more challenging than expected. For example, did you know that the enclosure of exposure scenarios is not in all cases mandatory? And how do you know whether the reported CLP hazard classification is correct or not?

The Chemical Compliance Coach can help you check your supplier’s SDSs, and assist you in asking the right questions to organisations higher up the supply chain. This can be of particularly importance when you need to calculate CLP mixture classification for your products, want to update your product SDSs, or wish to generate Workplace Instruction cards (WICs).

To avoid the principle of ‘garbage in, garbage out’, The Chemical Compliance Coach includes an extensive ‘Raw material SDS review phase’ to our CLP Classification Service and SDS Authoring Service. In this phase, we check the various (toxicological) inputs, identify data gaps and list any questions to be asked to the supplier. In our experience, 80% of the issues are quickly resolved. In the other cases, The Chemical Compliance Coach proposes a clear and pragmatic solution, which in case of an inspection is well-documented and justifiable. This way, The Chemical Compliance Coach guarantees high quality deliverables to ensure your REACH compliance.