GHS Compliance and the Safety Data Sheet

With the Globally Harmonized System GHS, which started back in 2009 in Japan, 2010 in Europe and is now anticipated for Q1 2012 in the United States, the requirements for material safety data sheets and labels were changed. Even under GHS, the safety data sheets, SDS as they will be known under GHS, must comply with the specific adopted law in the country, where it will be used. At KMK Regulatory Services we are ready to offer all products, documents and services, in compliance with GHS and the adopted legislations, worldwide.

When Japan adopted GHS back in December 2009, we began to write Japan-GHS MSDS in Japanese language for all our customers. More recently (January 20th, 2009), Europe via the REACH legislation opened the door to GHS for substances and mixtures, allowing the SDSs to carry BOTH the former DSD; DPD Directives using the Risk (R-) phrases and squared orange symbols, together with the GHS classes, categories and symbols, in Sections 2 and15 of the SDS. The essence in understanding the universality of GHS is to know that each country may adopt all or part of it and may also add country specifics, which make the system, rather dis-harmonized.

Changes to Safety Data Sheets language requirements for export under REACH

Recently, I was asked by a US based company exporting products to a number of EU countries if they needed to supply their product compliance documentation such as Safety Data Sheets (SDS) in the language of each country they were exporting to. Their European SDS’s comply with the EU DSD and DPD and they have always provided them in English only until now. However, with the introduction of REACH, this has completely changed. The Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) is an EU initiative to improve the protection of human health and the environment through better identification of the properties of chemical substances.

The most significant impact of REACH is to mandate chemical manufacturers and importers to determine the hazardous properties through testing of thousands of older industrial chemicals. Article 31(5) of REACH specifies that “The safety data sheet shall be supplied in an official language of the Member State(s) where the substance or preparation is placed on the market, unless the Member State(s) concerned provide otherwise.” It is then for you to enquire on the official language(s) spoken in each of the country you are exporting to.