Preparing Safety Data Sheets (SDS) – Part 5
Special cases and best practices
MSDS-Europe – Safety data sheet knowledge base – Preparing Safety Data Sheets (SDS) – Part 5: Special cases and best practices
In the previous parts of this series, we presented step by step how to compile a safety data sheet and what information each section of the SDS must contain.
To conclude, let’s consider a few additional factors and special cases that can arise during the preparation and use of SDSs.
We will cover exposure scenarios (attachments to the SDS), keeping SDSs up-to-date, and typical mistakes to avoid. In addition, we’ll offer some advice on how SDSs can be used effectively to improve workplace safety, and what support can be utilized if you are unsure about something.
(Remember that the detailed official Guidance on the compilation of safety data sheets document provides further explanations on these topics as well – it is available on the ECHA website.)
Exposure scenarios and extended SDSs
If a substance has certain hazardous properties and is manufactured or imported in large quantities, the REACH regulation may require developing an Exposure Scenario (ES).
An exposure scenario is a supplemental document that describes how to use the substance safely throughout its entire life cycle (from manufacture to use to disposal). When an exposure scenario is created for a substance, its SDS must be supplemented with the relevant information – this is when we speak of an “extended SDS” (ext-SDS). In practice, this means attaching the exposure scenarios to the SDS as annexes, or referencing them in Section 16.
What does this mean for the user?
If you purchase a hazardous substance and receive a 50-page SDS that has several annexes at the end, it likely includes exposure scenarios. These annexes contain detailed descriptions, for example, of how to use the substance safely in a given industry and what protective measures to apply so that the risk remains at an acceptable level.
Important: Downstream users (for instance, if you are a factory that uses a certain paint and the paint manufacturer has attached an exposure scenario for a solvent component) must check whether their own use of the substance is covered by the described scenario. If it is not, they need to inform the supplier, or they are obliged to perform their own risk assessment. This mechanism ensures that hazardous substances are truly used under conditions that are safe for those specific uses.
Exposure scenarios for mixtures: The situation is complicated by the fact that exposure scenarios are typically developed for individual substances, whereas most end users handle mixtures (finished products). According to guidance, the relevant information from the components’ exposure scenarios must be incorporated into the mixture’s SDS.
For example, if a cleaning product mixture contains a solvent for which an exposure scenario exists, then the cleaning product’s SDS sections 8 and 11–12 should take into account the limitations and protective measures described in that scenario. In practice, this is often achieved by attaching the component substances’ exposure scenarios to the mixture’s SDS as well, or by providing consolidated information from them. The key is that the user receives all important information – whether it’s a substance SDS or a mixture SDS.
Maintaining and updating SDSs in practice
We have already stressed the importance of keeping SDSs up to date.
Here are some practical tips to achieve this:
Tracking
Establish a system (even a digital register) to track the versions and dates of the SDSs for all materials used or sold by your company. Check regularly (for example, yearly) whether a newer version is available from your suppliers, and whether any changes in your own products have occurred that would require an SDS update.
Monitoring legislation
Stay informed about changes in chemical safety legislation. For example, if new hazard classes are introduced in the CLP regulation or exposure limits are revised, then the SDSs should be reviewed. A case in point was the adoption of Regulation (EU) 2020/878, which became mandatory in 2021 – many companies had to update their SDSs at that time to include the new elements.
Integrating new information
If you become aware of new toxicological or ecotoxicological information about your product (for instance, if it turns out that one component has more severe long-term effects than previously thought, or if an incident provides practical experience), then the SDS must be modified accordingly. This situation can also arise if the product finds a new use – in that case you may need to expand the use information in Section 1 and adjust the handling advice in Section 7.
Communication down the supply chain
Ensure that when an SDS is updated, all affected partners actually receive the new version. A common problem is that updates “get stuck” and fail to reach all users. It’s advisable to actively send the new version via email to every customer, and request confirmation of receipt.
If your SDSs are available for download on your website, it’s helpful to note something like “updated on [date]” to alert users that a new revision exists.
Common mistakes in SDS preparation – what to watch out for
Even experienced companies can have errors in their safety data sheets.
Here are some common mistakes or gaps to avoid:
Incorrect or incomplete classification
Sometimes Section 2 of the SDS does not list the hazard classes correctly, or an important H statement is missing. For example, a mixture might cause mild skin irritation, but the SDS does not include “Skin Irritation Category 2, H315.” This can be misleading.
Solution: Always use up-to-date classification information, and leverage the component data to determine the correct classification.
Inconsistency between sections
A frequent mistake is that different parts of the SDS contradict each other. For instance, Section 9 might state that the product is not soluble in water, but Section 6 recommends washing spills away with water. Or Section 2 indicates the product is not flammable, but Section 5 is written as if it were flammable. These contradictions suggest the SDS was assembled carelessly from templates.
Solution: Check the SDS thoroughly as a whole. Read through it for logical consistency, not just section by section.
Overly generic statements
Sometimes an SDS is filled with generic phrases that do not offer concrete guidance. For example: “Avoid all possible exposure,” or “Use appropriate protective equipment,” without specifying what “appropriate” means. Such vague advice is not useful.
Solution: Be specific – name the exact protective equipment needed, the materials or conditions to avoid, and the concrete steps to take.
Outdated references or legislation
In some SDSs, you might still find references to old EU directives or regulations that are no longer in force, simply because the data sheet hasn’t been updated for years. For example, it might refer to the old orange hazard symbols or use classification from the pre-CLP DSD/DPD system.
Solution: Regularly review your SDSs and update the regulatory references (Section 15) to reflect current legislation.
Language/translation errors
For SDSs in the local language, a common issue is that literal translations from English are left in or awkward phrasing is used, which makes understanding difficult. For example, writing “Robbanás biztos berendezés” instead of the correct “Robbanásbiztos berendezés” (the proper Hungarian term for “explosion-proof equipment”). This seems minor but can cause confusion.
Solution: Have the SDS translated by a qualified professional and, if possible, get the final text proofread by a native-speaking expert.
The SDS as a workplace safety tool
A well-prepared safety data sheet is not just a mandatory document to keep on a shelf for inspections. Its real value lies in helping to make everyday work safer.
Some tips on how to use SDSs effectively:
Safety training
Use the information in SDSs to train employees. In safety training sessions, take out the relevant data sheets, show the hazard symbols, and discuss what the H and P statements mean.
For example, if you use solvents in a workshop, the SDS can explain why you need proper ventilation and why you must avoid open flames.
Risk assessment
Workplace chemical risk assessments are based on the properties and recommendations described in the SDS.
For instance, using the data in Section 8, you can determine whether local exhaust ventilation is sufficient or if workers also need respiratory protection. It’s wise to attach the relevant SDSs to your risk assessment documentation and to reference their guidance in your evaluation.
Emergency planning
For emergency response plans (for accidents or fires), always take into account the first aid and fire-fighting information from the SDS.
In a facility handling chemical substances, the emergency plan might even include as an annex the SDSs of the main hazardous materials, so that first responders or firefighters can access them immediately.
Communication with suppliers
If something in an SDS is unclear, do not hesitate to ask the supplier (manufacturer) for clarification. Using the contact details provided in Section 1 of the SDS, you can request additional information.
For example, if you are unsure about which material or thickness of protective gloves to use, it’s worth asking the supplier to clarify the recommendation.
Expert assistance and resources
When preparing and managing safety data sheets, you don’t have to solve everything on your own – there are many sources of help available:
Official guides
The European Chemicals Agency (ECHA) and national authorities have published guidance documents (indeed, this series of articles is based on one such guide). These guides – for example, the “Guidance on the compilation of safety data sheets” – provide detailed explanations, examples, and templates. Use them whenever you are unsure about the interpretation of a requirement.
Software and templates
Numerous commercial software tools are available that assist in creating SDSs. They contain databases with regulatory data and hazard information, and can automatically generate the text in multiple languages. While these are useful, they do not replace human expertise. Always review an SDS produced by software for accuracy and completeness.
Consultancy experts
If your company does not have its own SDS specialist, you can turn to chemical safety consulting firms. For example, MSDS-EUROPE. is a Hungarian company specialized in chemical safety that offers services to prepare, review, and translate safety data sheets, as well as to submit dangerous mixture notifications to EU databases (such as poison center notifications, PCN).
An external expert stays up-to-date with the latest regulations and, through experience, can compile an SDS more quickly and accurately than trying to do it in-house without the necessary expertise. This approach is especially worthwhile if you work with many hazardous substances or supply products to multiple countries (requiring SDSs in multiple languages).
Authority and industry helpdesks
The EU has a REACH-CLP Helpdesk network. You can direct questions to these helpdesks if you are unsure about a particular requirement. Additionally, industry associations (e.g. chemical industry associations) can provide support and training on this topic.
This 5-part series has provided an overview of the main steps and considerations in preparing safety data sheets.
We hope that the information presented will be useful for manufacturers, distributors, and users alike. If there are still uncertainties in your company regarding the management of SDSs, it is advisable to consult with experts.
The original guidance document on which our articles were based can be accessed here: Guidance on the compilation of safety data sheets (ECHA, 2021).
Preparing a safety data sheet is not an administrative formality, but a task that requires professional competence. It is wise to work with a service provider or expert who is familiar with the REACH and CLP rules and capable of staying up-to-date with changes.
Further parts:
- Part 1: Introduction and Regulatory Background
- Part 2: Responsibilities and the SDS Compilation Process
- Part 3: The first 8 sections of the SDS in detail
- Part 4 The remaining SDS sections (9–16)
Thank you for joining us in this series!
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