Useful background information for downstream users on safety data sheets.

Safety data sheet knowledge base – About the safety data sheet for downstream users

The safety data sheet as a communication tool

Safety data sheets are important communication tools in the supply chain.
The help all the members of the supply chain to meet their responsibilities in relation to the management of risks arising from the use of substances and mixtures.

Downstream users are informed in the form of a safety data sheet of the risks arising from their identified use and of the measures to take to control these risks.

Exposure scenario

Some safety data sheets also have an attachment that is called an exposure scenario. The exposure scenario provides more accurate data on safe use and on reducing the exposure than a safety data sheet.

If the exposure scenario does not cover the intended use, contact with the supplier should be made.
Otherwise, downstream users should develop their own chemical safety report.

Tasks to do if you do not get a safety data sheet for the purchased substance/mixture

This does not mean that you do not have to implement (and communicate toward the other members of the supply chain) those risk management measures that the supplier disclose otherwise (in a written statement, on a technical data sheet, in specifications, etc.).

The fact that we did not get a safety data sheet is likely to mean, that the substance or mixture is not considered hazardous.

Nevertheless, we should contact them and ask for a safety data sheet (in some cases legislation allows suppliers to provide a safety data sheet only upon request).

Tasks to do after receiving a safety data sheet

It should be checked wheter the safety data sheet contains a registration number.

If the registration number is included in the safety data sheet, you will have 12 months to comply with the REACH requirements specified for downstream users.

If a substance has not yet been registered and no registration number is issued, you should follow the instructions given in the safety data sheet.

You should check the information on hazards and on risk management. You should also check the implementation of risk management measures and the fact wheter any substance presented on its own or as a part of a mixture is subjected to authorization or some kind of restriction.

If the supplier does not support certain uses in order to protect human health or the environment, they must indicate this in Section 16 of the safety data sheet or among the information provided in compliance with Article 32. If the contraindication is not justified, the downstream user has the right to request further information or justification.

Task to do in case of uses advised against

You should put an end to the usage of the substance or mixture.
Safe use can be demonstrated with the creation of a downstream user chemical safety report. For this purpose, you should evaluate the use of the substance or mixture more in-depth than the supplier and, where appropriate, you should modify the conditions of use.

Tasks of the downstream users producing mixtures regarding safety data sheets

After the classification has been made, we will be able to tell whether or not we should provide a safety data sheet to our customers regarding the particular mixture.

Safety data sheet should be provided for professional users in the following cases

If a substance or mixture is classified as hazardous
If a substance is persistent, bioaccumulative and toxic or very persistent and very bioaccumulative in accordance with the criteria set out in Annex XIII.
If a substance is included in the list established in accordance with paragraph (1) of Article 59,

If the mixture does not qualify as hazardous, the customer may request the safety data sheet in the following cases

It contains a hazardous substance in a concentration of ≥ 1 % by weight for non-gaseous mixtures.
It contains a hazardous substance in a concentration of ≥ 0,2 % by volume for gaseous mixtures.
It contains in an individual concentration of ≥ 0,1 % by weight for non-gaseous mixtures at least one substance that is carcinogenic category 2 or toxic to reproduction category 1A, 1B and 2, skin sensitiser category 1, respiratory sensitiser category 1, or has effects on or via lactation or is persistent, bioaccumulative and toxic (PBT) in accordance with the criteria set out in Annex XIII or very persistent and very bioaccumulative (vPvB) in accordance with the criteria set out in Annex XIII.
If it contains a substance which is included in the list established in accordance with paragraph (1) of Article 59.
It contains a substance for which there are Community workplace exposure limits.

In cases where the above exceptions are not met – thus no safety data sheet is needed to be compiled – for the substance or mixture, suppliers must provide the following information to all their downstream users and distributors (Article 32 to REACH):

If the substance is subjected to authorization, the details of the authorization granted or, if the authorization is refused, the appropriate information on the details of the restriction.
Any relevant information about the substance that is necessary to enable appropriate risk management measures to be identified and applied.
The registration number(s), if available, for any substances for which information is communicated under the points above.

No safety data sheet shall be compiled for hazardous substances or mixtures for consumer use on the market where sufficient information is provided to allow users to take the necessary measures to protect human health, safety and the environment, unless the downstream user or the distributor asks for it in particular.

You can find our article on the content and format elements of a safety data sheet here.

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