MSDS compliance - What you need to know about it.
If you need to create MSDSs, you need to know what contributes to MSDS compliance. While some sophisticated software or external services can take care of keeping your MSDSs compliant, it is nevertheless useful to be aware of the basic elements contributing to MSDS compliance, because ultimately you are responsible and liable for your own MSDSs.
One obvious element of MSDS compliance is support for language translations. The MSDS must be in the language of the country where your product will be used. It is worth noting that some countries have more than one official language (Canada, Belgium, Switzerland, etc), so the MSDS must be in multiple languages. In addition, it is good to inquire with local authorities whether an MSDS in another language is acceptable. For example, an English MSDS can be accepted in a non-English-speaking country where English is widely used.
Another element of MSDS compliance is support for regulatory lists. If you are creating an MSDS for a specific country, you need to make sure that you are tracking all the regulatory lists pertinent to that country and that are required for display on MSDSs.
MSDS compliance is also about ensuring that your products are classified accurately, as per the regulations in place. For example, you need to be aware of the thresholds for disclosing certain substances, and the criteria that trigger product classifications.
Particular attention should also be paid to local regulations that may be overlooked. For example, people assume that an SDS for the EU that is compliant with REACH and CLP and that is translated fully in German is compliant for Germany. This is not the case, as Germany has its own specific regulations that require additional information to be present on an SDS for Germany.
Finally, MSDS compliance is also about knowing when you are required to update your MSDSs to keep them in compliance. This is especially compounded by GHS and REACH. For example, if new test data is available that would change the classification of your product, you may need to update your MSDS. Similarly if new REACH exposure scenario information, provided by your supplier, would alter the exposure scenario information communicated to the downstream users of your products, you may need to update your EU SDS.
It is important to note that MSDS compliance is not a one-time task, but an on-going process throughout the lifecycle of your product. Given the complexity associated with MSDS compliance, the conclusion is that you may need products and services from a vendor that will act not just as a vendor, but an engaged compliance partner.
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