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What is an MSDS (Material Safety Data Sheet)?
A safety data sheet is a document which is to inform users about potential hazards resulting from the use of dangerous substances or preparations (mixtures). Additionally, it must contain the basic physical and chemical data concerning the composition of such substances and information about conduct procedures in case of coming into contact with a particular liquid. This document is required in all EU countries, and it is the chemical producer that is responsible for its compilation. Such a safety data sheet must be accessible both during transportation and storage of said substances. In accordance with the law, a safety data sheet must be supplied in the official language of the country in which a given substance or preparation is being used unless the member states provide otherwise.
Who are safety data sheet for?
We are all users of chemical substances. Every day we are exposed to hazardous agents, such as, for example, disinfectants. In the case of hazardous substances used for domestic purposes, the manufacturer has to provide on the package label all important information for the safe use of the given agent. However, there is no obligation for the manufacturer to sell the agent with its safety data sheet.
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The situation is different when using hazardous substances in companies (regardless of whether the substance is purchased for personal use, e.g. for cleaning, or for production purposes). Then, the producer of the chemical substance has an obligation to deliver the safety data sheet together with the substance sold. In contrast, the user of a substance (the company that buys and uses a substance) is required to obtain the SDS from the manufacturer and use it. What does it mean in practice?
- The issue of safety data sheets can be considered in two ways:
- a dangerous substance used as raw material to manufacture a product,
- a dangerous substance as a harmful factor present in the workplace of an employee.
A dangerous substance used as raw material to manufacture a product
In the case of a substance used as a component of a finished product, the manufacturer of the product must take into account chemical composition of a substance and relate it to the legal requirements that apply to the products he creates. New Approach directives, including the Toy Safety Directive (2009/48/EC), the RoHS 2 Directive (2011/65/EC) and the Directive on medical devices (93/42/EEC) contain an outright ban on the use of certain substances in toys, electrical and electronic and medical devices. This applies, for example, to phthalates, a number of heavy metals, including cadmium and mercury, as well as PBB (polybrominated biphenyls), and others. In addition to bans on the use of certain substances, manufacturers of toys and other types of products are required to put on their products (or in their documentation) information about allergenic compounds. Whether a product contains a compound of limited use can be determined from the data sheets of substances that have been used to manufacture the product. Therefore, the use of SDS is necessary for assigning the CE marking to products that are subject to the European directives.
A dangerous substance as a harmful factor present in the workplace of an employee
The second case, which should be considered, are the responsibilities of the employer, the employees of which use dangerous substances in a company. According to the Labour Code, such an employer must maintain a list of dangerous substances used in the plant. He should also make the employees acquainted with the conditions of safe use of such substances, and provide them with personal protection when working conditions require it. It is from SDS that the employer will learn what safety measures he should take. In addition, SDS contain information on how to react in case of an accident (e.g. spilling a hazardous substance on oneself), leakage to the environment, as well as the storage and transport of these substances. The issue of storage is particularly important in the case of flammable substances and explosives, when the improper storage increases the risk of fire or explosion. In practice, an employer who want to fill his duties should:
- have the updated SDS of all hazardous substances used in a plant and prepare a list of such substances, with reference to the SDS,
- acquaint employees with the contents of the SDS and have the confirmation of this fact in the form of an employee’s signature,
- provide, if necessary, instructions for dealing with substances, and all measures of individual and collective safety necessary for the safe use and storage of the substances.
A dangerous substance as a harmful factor present in the workplace of an employee
The content of Material Safety Data Sheet is set out in the REACH Regulation and should be updated if the composition of a hazardous substance changes, if the law on chemicals changes or if the scientific knowledge concerning the substance changes, which will affect the assessment of the substance safety. Safety Data Sheet must have the following information:
- identification of the substance/preparation;
- identification of the company;
- identification of hazards;
- composition/information on ingredients;
- first aid;
- procedures in the case of fire;
- proceedings in the case of accidental release to the environment;
- handling the substance/preparation and its storage;
- exposure controls/personal protection;
- physical and chemical properties;
- stability and reactivity;
- toxicological information;
- ecological information;
- waste management; transport information;
- regulatory information;
- other information.
- The lack of any of the information should arouse the suspicion of a user of a substance as to the credibility of the SDS.
Changes in safety data sheets after 1st June 2015
Since 1 June 2015, the provisions of the CLP Regulation came into force for the labelling of dangerous chemical mixtures. This means changing the REACH provisions, and in practice results in the need to update safety data sheets of mixtures. Users of chemicals should figure out whether the changes relate to the products purchased by them and, if necessary, request their suppliers to make the updated SDS available.
Pictograms according to the old law
According to earlier regulations the following pictograms were in force:
Explosive (E)
Oxidative (O)
Corrosive (C)
Extremely flammable (F +) and Flammable (F)
Very toxic (T +) and Toxic (T)
Harmful (Xn) and Irritant (Xi)
Dangerous for the environment (N and/or R52, R53, R59)
There were no pictograms for the following substances:
- Flammable (R10)
- Sensitising (R42 and/or R43)
- Carcinogenic – classified into one of three categories (e.g. Carcin. Cat. 3)
- Mutagenic (Muta.). – classified into one of three categories (e.g. Muta. Cat. 1)
- Toxic for reproduction (Repr.) – classified into one of three categories (e.g. Repr. Cat. 2)
Changes of pictograms after 1 June 2015
After the entry into force of the CLP Regulation 1272/2008 since 1 June 2015, the following pictograms are in force:
Pictogram GHS01
Pictogram GHS02:
Pictogram GHS03
Pictogram GHS04:
- Substances corrosive to metals, hazard category 1
- Skin corrosion, hazard categories 1A, 1B, 1C
- Serious eye damage, hazard category 1
- Acute toxicity (oral, dermal, inhalation route), hazard categories 1, 2, 3
- Acute toxicity (oral, dermal, inhalation route), hazard category 4
- Skin irritation, hazard category 2
- Eye irritation, hazard category 2
- Skin sensitisation, hazard category 1
- Toxic effect on target organs – single exposure, hazard category 3
- Irritating to respiratory system
- Narcotic effect
- Sensitisation to respiratory route, hazard category 1
- Mutagenic effect on reproductive cells, hazard categories 1A, 1B, 2
- Carcinogenicity, hazard categories 1A, 1B, 2
- Reproductive toxicity, hazard categories 1A, 1B, 2
- Toxic effect on target organs – single exposure, hazard categories 1, 2
- Toxic effect on target organs – repeated exposure, hazard categories 1, 2
- Aspiration hazard, hazard category 1
Pictogram GHS09
- Hazardous to the aquatic environment
- Acute threat, category 1
- Chronic threat, categories 1, 2
There are currently no pictograms for the following hazard classes and categories:
- Hazardous to the aquatic environment – chronic threat, category 3, 4
- Explosives of subclass 1.5
- Explosives of subclass 1.6
- Flammable gases, hazard category 2
- Self-reactive substances and mixtures, Type G
- Organic peroxides, Type G
- Reproductive toxicity, effects on lactation or harmful impact on breast-fed babies, additional class of threats
The principle of priority
Moreover, if a dangerous substance or a dangerous mixture cause more than one hazard, they do not need to have different pictograms in the SDS. The so-called ‘principle of priority’ applies. According to it:
- if a pictogram presents a skull and crossbones, it should not additionally have an exclamation mark;
- if a pictogram shows corrosive action, it should not additionally have an exclamation mark if it relates to eye or skin irritation;
- if a pictogram related to health hazard and shows the sensitising effect on the respiratory system, t should not additionally have an exclamation mark if it has a sensitising effect on the skin or if it applies to eye or skin irritation.
Implications of changes for users of hazardous substances and mixtures
Users of substances and mixtures should ensure to use the updated data sheets and properly labelled containers with hazardous substances and mixtures. Therefore, substances and the data sheets present in a plant should be inspected and, if necessary, ask the suppliers to update them. Also employees who are involved in purchases, should make the suppliers aware of the changes to ensure they provide correctly labelled compounds.
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