SDS Compliance: Ways to Tackle Supplier Document Non-Conformities

In the highly regulated chemical industry, compliance with legal requirements is not just about adhering to rules… it’s about ensuring safety, protecting the environment, and maintaining trust. Under the REACH Regulation’s CLP (Classification, Labelling, and Packaging) guidelines, chemical suppliers must ensure SDS compliance and provide current and comprehensive documents for all the chemical products they distribute.

About Safety Data Sheets: Essential Information for Chemical Safety

According to the European Chemicals Agency (ECHA), Safety Data Sheets are essential for communicating comprehensive information about the properties of substances or mixtures, their hazards, and safe handling instructions throughout the supply chain. They include instructions for safe handling, disposal, transport, as well as guidelines for first aid, fire-fighting, and exposure control. The format and content of SDSs are meticulously defined under Annex II of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation to ensure consistency and accessibility of information.

Ultimately, SDS compliance is about:

• Safeguarding the health and safety of your workforce by informing users of potential hazards and proper handling procedures.
• Protecting the environment by preventing chemical incidents.
• Maintaining operational efficiency through informed handling and use of chemicals.

These key aspects underscore how SDS compliance is integral to preserving the reputation and financial stability of businesses through transparency and responsible practices. Yet, in December 2023, ECHA reported that the overall rate of SDS non-conformities was still as high as 35% in the EU.

Suppliers’ Role in SDS Compliance

As the primary providers, suppliers bear the critical responsibility of ensuring that all SDSs meet these stringent standards to support industry-wide safety and compliance.

With continuous updates which keep redefining the rules of SDS Authoring, SDS compliance seems like an endless battle. Examples include the REACH Annex II Amendment, which became mandatory in December 2022 and required suppliers to once again review their SDSs to fulfill their regulatory obligations and support safe use of chemicals in the EU. Other example, in the United States, the Occupational Safety and Health Administration (OSHA) will soon implement HazCom 2024, aligning with the Globally Harmonized System (GHS) and updating standards from HCS 2012. These changes emphasize the global and dynamic nature of SDS compliance.

While on paper, achieving compliance with regulations seems straightforward. In practice, suppliers face resource constraints and interpretation hurdles, leading to delays in updating documents and customers dissatisfaction, hence the pressing need for suppliers to invest in tools and expertise to easily follow up on these amendments.

Common Challenges in Suppliers Documents Sourcing

At Lisam, we strive to help suppliers meet their regulatory obligations and achieve a safer and more sustainable work environment by facilitating SDS compliance. Backing ECHA’s 2024 report, some of our own customers have highlighted issues in managing suppliers SDSs such as collecting missing documents, minor to major non-conformities in provided documents and escalation difficulties, which significantly affect their operations.

To tackle these challenges, Lisam offers a wide range of products and services to collect and analyze the quality of supplier SDSs. In particular, through our advanced SDS indexing process, we were able to uncover a range of compliance issues that underscore the critical need for improved SDS management.

Key Findings Include:

• Outdated Documents: Many SDSs predate the June 2015 CLP Regulation update. As a result, they are non-compliant due to outdated hazard classifications or missing information.
• Inconsistencies Across Languages: Discrepancies in chemical compositions and safety instructions are common when indexing SDSs in multiple languages. This often occurs because suppliers provide different document versions for different regions.
• Regional Classification Errors: Misclassifications based on regional standards are frequent. SDSs often incorrectly apply hazard classifications meant for one region to another, leading to potential safety risks and compliance violations.
• Documentation Errors: Mismatches in hazard (H) statements or precautionary (P) statements for the designated region are common. These errors often result in incorrect or inadequate hazard communication.

Lisam’s Solutions for Enhanced SDS Compliance

At Lisam, our commitment to supporting clients in the chemical industry is grounded in ensuring that Safety Data Sheets (SDS) meet all compliance standards. We believe that tackling SDS compliance issues effectively means addressing them right at the source: the suppliers.

That’s why, we focus on addressing SDS compliance challenges effectively by developing advanced tools designed to support suppliers in streamlining this critical process. In particular, our SDS authoring tool offers comprehensive SDS compliance management in line with global regulatory standards, our SDS distribution tool, not only helps with the timely delivery of the right document but also offers solutions to manage SDS requests. Finally, our chemicals management solution simplifies chemical inventory and hazard communication.

If you are a supplier and struggling to keep up, remember you don’t have to face your SDS compliance challenges alone!

To see how these tools can specifically enhance your operations, request a free consultation with our experts.

Discover now how Lisam can transform your approach to chemical safety and SDS compliance, ensuring your operations are both safe and efficient.

Source: https://echa.europa.eu/documents/10162/2304648/wg_ref11_project_report_en.pdf/c9c78941-48bf-c6eb-38ca-11e55e18f889?t=1733136406554