If you compile/receive EU-compliant safety data sheets, you are probably by now aware of the updated requirements to the Annex II to EU Reach Regulation (EU 2020/878); which includes the addition of ATE data, SCLs, M-factors, endocrine disruptor information, and UFIs.
Although it could be argued that the incorporation of this additional information in the SDS is useful, I think that it raises an important question…should we rely on information provided by the supplier SDS– without verifying it before we use it in our own SDS?
Always verify the data – due diligence
As an SDS author, I understand how useful (at least in theory) it would be to have this kind of information/data available in supplier SDS. However, I would still do my own due diligence.
That is, I would check/verify the Annex VI (harmonised classifications), conduct my own online search for toxicology/ecotoxicology /physicochemical data, etc. Take a look at the list of resources I have provided in the website.
Reputation is everything
Therefore I would not rely solely on information which is provided by the supplier SDS. The reason being that it may be inaccurate and/or incomplete. Remember, from your customers perspective, any inaccuracies in your SDS will be your fault-irrespective of whether they came from your supplier information. Reputation is everything!
As I have mentioned in Toxic Blog #1, I would also take time to carefully read the supplier SDS and check that it is not only compliant but consistent and of course correct.
Document all your information sources
I would also recommend that you do the same and make a record of your information sources. This is something which I always emphasise on my training courses.
Competent SDS authors and refresher training
Another important reminder from the regulation is that there is a requirement for SDS authors to be ‘competent’ and to attend, where necessary ‘refresher courses’.
So if you would like to refresh your authoring skills, learn more about writing compliant and, very importantly write USEFUL safety data sheets, then take a look at the upcoming webinar ‘How to write compliant Safety Data Sheets – including the recent Annex II updates’.
If you are completely new to writing safety data sheets, then you might want to take a look at the longer training course ‘Introduction to writing safety data sheets’.