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When Should You Update or Revise Your SDSs?

By Little Pro on 2016-09-06 Views:  Update:2017-01-18

Generally, chemical suppliers need to periodically review, revise, and update their safety data sheets (SDSs). Changes are made as necessary as new hazard info is found, new information about protective measures is ascertained, or changes are made to product information (i.e., composition, use). In this article, we have summarized the regulatory requirements for SDS revisions in major countries that have adopted GHS. EU, USA, Canada, China, Japan, Korea, Taiwan, Singapore and Australia are covered.

Europe

The conditions under which an SDS must be updated and re-issued in EU are given in Article 31(9) of EU REACH regulation. REACH requires suppliers to update the safety data sheet without delay on the following occasions: 

  • as soon as new information which may affect the risk management measures, or new information on hazards becomes available (i.e, new classification);
  • once an authorisation has been granted or refused;
  • once a restriction has been imposed;
  • any updates following registration shall include the registration number.

Only above changes give suppliers a legal obligation to provide updated versions (on paper or electronically) to all recipients to whom the substance or mixture has been supplied within the preceding 12 months. REACH does not differentiate a “major” change from a “minor change”. REACH does not require periodic SDS review either.

Ref: ECHA guidance on SDS compilation

USA

Chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards shall revise SDSs within 3 months. The labels shall be revised within 6 months. If the chemical is not currently being produced or imported, the chemical manufacturer or importer must add the information to the SDS/labels before the chemical is introduced into the workplace again.

Even though OHSA’s hazard communication standard does not clearly define what significant information is, it is generally assumed that it includes the change of classification, new hazards, new occupational exposure limits, and new risk management measures.

Ref: OSHA Hazard Communication Standard 2012

Canada

Similar to USA, Canada requires a supplier to update SDSs when the supplier becomes aware of any "significant new data” that changes how the hazardous product is classified, or when there are changes to the way you will handle or store the product. SDSs will be required to be updated within 90 days of the supplier being aware of the new information.

Under WHMIS 1988, there was a requirement for suppliers to review and update SDSs every 3 years. This requirement was deleted in WHIMS 2015.

Ref: Canada WHIMS 2015 FAQs

China

In China, both SDS compilation standards GB/T 16483-2008 and GB/T 17519-2013 require suppliers to keep the information in SDSs accurate. The rules for the safe use of chemicals at workplace (1997) further require manufacturers to revise SDSs every 5 years or revise SDSs (and provide updated version to recipients) within 6 months since any new hazard info is made available.

Ref: The rules for the safe use of chemicals at workplace (1997)

Japan

Japan’s JIS Z 7253 requires a supplier to update safety data sheet without delay if the supplier becomes aware of any new information concerning a chemical, and provide revised edition to recipients. It is not clear what kind of information triggers the need to update SDSs. It is not clear whether all previous recipients should be provided with the updated SDSs either.

Ref: JIS Z 7253 Hazard Communication Based on GHS

Korea

Korea requires suppliers to update SDSs and provide updated versions to recipients when there are any changes made to the following sections in SDSs.

  • Product & company identification
  • Hazards identification
  • Composition Information on Ingredients
  • First aid measures
  • Explosion, fire-fighting measures
  • Accidental release measures
  • Handling and storage
  • Exposure controls and personal protection
  • Regulatory information

It should be noted that Korea’s Standard for Classification Labeling of Chemical Substance and Material Safety Data Sheet is reviewed and updated every 3 years (latest version is MoEL notice 2016-19). It means that you may need to review your SDSs every 3 years to make sure that they are always compliant with the latest hazard communication requirements.

Ref: Korea MoEL notice 2016-19

Taiwan

A manufacturer, importer, supplier, or employer shall check the accuracy of a Safety Data Sheet (SDS) based on the actual circumstances and update it as needed. A Safety Data Sheet shall be reviewed at least every 3 years. Records of SDS updates such as content, date, and version revision, shall be kept for 3 years.

Ref: Regulation of Labelling and Hazard Communication of Hazardous Chemicals

Singapore

Suppliers and employers must update SDSs and labels within 6 months since new information concerning a chemical is made available. Suppliers should also periodically review label and SDSs every 5 years even if no new information has been provided.

Ref: GHS in Singapore

Australia

In Australia, the manufacturer or importer of the hazardous chemical must:

  • review the SDS at least once every 5 years; and
  • amend whenever necessary to ensure that it contains accurate information, for example if new data becomes available which changes the chemical’s hazard classification.

Ref: WHS Regulations FAQ

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