How can I include safe use information for my ingredients in the SDS of the formulated product?
If you formulate mixtures using substances for which exposure scenarios (ESs) have been provided by the supplier(s), you are obliged to include the safe use information in your product Safety Data Sheets (SDSs) where relevant. There are multiple ways in which this can be done:
- Forward ESs for each mixture component to your customer without consolidation
- Extract relevant information on Risk Management Measures (RMMs) and Operational Conditions (OCs) and include it in the main body of the product SDS
- Consolidate the received ESs into new “Mixture ES” annexed to SDS
The first option is by far the quickest and easiest, but your customer may experience difficulty identifying which information is relevant to him. The second option is in that sense a great improvement, but it may be a challenge to accommodate all the relevant safe use information in the SDS, especially when you have identified multiple uses in your market. Option 3 requires a new safety assessment for the formulated mixture, either based on the substance(s) identified to drive the risk of the mixture (top-down approach), or based on generic use scenarios, established on sector level (using Generic Exposure Scenarios, bottom-up approach).
Please note that regardless of the approach taken, the (relevant information in the) ES must be translated into an official language of the member where you place the formulated product on the market.