On 30 December 2011, a Japanese isobutane exporter called for help when their products were held in custody at Guangzhou Customs due to a non-compliant SDS.
On 30 December 2011, a Japanese isobutane exporter called REACH24H for help when their products were held in custody at Guangzhou Customs for the reason of non-compliant SDS. Enforcement officers claimed their SDS sections and titles were not complying with required format of China’s recommended standard on Safety Data Sheet for Chemical Products – Content and order of sections (GB/T 16483-2008). Even worse, most of the hazard statements and risk management measures were not standard Chinese language but rather translated using online translators.
This has not been an accidental event in the supply chain communication, as similar trouble has happened to Chinese exporters on their way to the EU markets. Why does the problem keep happening? Which aspects in SDS preparation should chemical manufacturers and distributers be aware of?
The following are some tips collected by the SDS team of REACH24H, which we hope will be useful for SDS preparation or translation.
1) Be familiar with the local SDS writing standards
It is necessary that your SDS structure follows the corresponding SDS writing standard of your target markets. In the EU, Regulation No 453/2010 provides the general framework for safety data sheet based on the EU CLP regulation; in China, GB/T 16483-2008 is the main standard for Chinese SDS writing.
2) Comply with the accepted SDS framework
It is necessary that your SDS structure follows the fixed section titles and subtitles required in the SDS writing standards. Companies should take care to check if your Chinese sections or subtitles and your structure order are consistent with the framework provided.
The section on hazard classifications, usually existing as Section II in a safety data sheet, should be identified according to specific standards of your target market. Under China GHS, it is the 26 GB standards.
3) Emergency telephone for Chinese SDSs
Emergency telephone number is a mandatory requirement for China GHS-based SDSs. The telephone must be a Chinese domestic landline rather than cell phone number, and the telephone must be available in 24 hours with professional receptionist on standby. If it is very difficult for you to provide this emergency contact, you may resort to the National Registration Center for Chemicals (NRCC) for help. This public institute has now opened an emergency phone service qualified to provide 24-hour professional help.
4) The principle of consistency and completeness in SDS preparation
The principle of consistency and completeness not only governs the overall format of your SDS but also applies to coherence of the technical details in your SDS.
To be specific, in Chinese SDS Section II, the physical hazard information should be consistent with the physico-chemical data provided in your Section IX; the human health hazard information should be consistent with the toxicological data in Section XI; and the environmental hazard information consistent with the eco-toxicological data in Section XII.
Still, all those data in the second section should be able to align with the following descriptions in sections about first-aid measures, fire-fighter measures, safe storage and disposal and personal protection measures.
Some of our client experiences show that relevant enforcement authorities can be meticulous in finding some technically conflicting data information in SDSs from foreign suppliers, i.e. inconsistent data information. For instance, when you identify the flash point of certain liquid substance at 40 °c but your SDS doesn’t demonstrate any information on the flammability of the substance in the part of physical hazard. This will be counted as inconsistent data and thus a non-standard safety data sheet.
Some of the Chinese companies are inclined to imitate an existing similar SDS document and copy data values from various sources. In this case, it is particularly important to pay attention to SDS coherence principle and make sure your selected data are consistent throughout the report.
5) Timely updates of new information in your SDS
A safety data sheet is an obligation in the supply chain communication; therefore you should expect to keep it updated regularly. Every time there is a change to the product information, company information or substance usage or hazard information, you have to make plans to update the SDS and inform your downstream users.
6) Composition information and confidentiality
In general, all compositions should be listed together with their concentration percentages. It is acceptable to adopt confidential claims in the preparation of SDS and then you may list only a generic name for certain composition in your substance. Yet if the component substance is classified as hazardous, you still have to provide the hazard information or consult regulatory experts before you act.
(Corrigendum: If your component substance contributes to the hazard properties of the mixture but you still have confidential concerns, you can keep the chemical name secret but hazard information in question is mandatory. )
It seems that importers and exporters might have to take some note of the regulatory terminology consistency in the SDS language.
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