The challenges SME face with SDS

What are SDS for?

Safety Data Sheets (SDS) are a key to chemical safety safety, providing information on the hazards associated with chemicals and the precautions required for their handling, storage, emergency response and disposal.

The SDS deliver safety working together with labelling of containers. The SDS provides more detailed information than, the product label. But the label is more visible and immediately accessible, while the SDS provides the supporting detail.

When examining issues with SDS, it is important to consider labelling as well. Organisations often have the required SDS available—possibly dog-eared and covered in workshop grime—but fall short when it comes to ensuring containers are correctly labelled.

Figure 1 – Typical SDS scenario

Why SDS fail to deliver safety to SME?

Common issues include:

• Too long and technical for most workers to use effectively.
• Can add clutter to workplaces rather than improve safety communication.
• Difficult to keep current.
• Often need to be obtained reactively, as suppliers do not always provide updated SDS with subsequent deliveries.
• Important information can be buried within lengthy documents.

The challenge is not that SDS are unnecessary – they are a key to chemical safety. Rather, the amount of information they contain can make it difficult for workers to quickly find the information they need.

Why do I need to have SDS scattered around my factory?

You don’t.

The requirement is that SDS must be readily accessible.

This means workers must be able to easily obtain the SDS, or a condensed version of its key information, whenever they need it.

Businesses must still obtain and retain the full SDS where required. However, WorkSafe allows key information from the SDS to be made readily accessible through a condensed version or safety data card.

For many small businesses operating from a single site, a centrally located SDS repository may be sufficient, provided workers can readily access it whenever required.

The SDS can be held:

• In hard copy.
• Electronically.
• Through a combination of both.

If stored electronically, it should be located somewhere readily accessible to workers, such as a shared network drive or cloud-based document system.

If kept in hard copy, a dedicated folder or waterproof document holder is often sufficient.

Accessibility is about availability when needed. An SDS locked in an office after hours, stored only on a manager’s computer, or located in another building may not be considered readily accessible.

Do I need all 16 pages of an SDS or can I use a short version?

The full SDS remains a key to chemical safety. It is an important reference document and may be essential in laboratories, chemical manufacturing environments, emergency situations, or regulatory investigations.

However, for many workplaces, the full SDS contains far more information than workers require for day-to-day use. This can make it difficult to identify the key safety information quickly.

As a result, the important information may not be read or understood.

Is there a short form of SDS that can be used to deliver safety?

Enter the Condensed Version (sometimes referred to as a Safety Data Card or Product Safety Card).

WorkSafe states:

“Instead of the SDS, you can make a condensed version of its key information readily accessible.”

While some suppliers provide these, many businesses create their own using information from the SDS.

To be effective, a condensed version should contain:

• Substance name.
• Hazard pictograms.
• HSNO classifications or GHS hazard statements.
• Key hazards presented by the substance.
• Precautions for:
  • Handling.
  • Storage.
• Required PPE.
• First aid instructions.
• Firefighting measures.
• Emergency contact numbers.

The objective is not to reproduce the SDS in a smaller font. The objective is to provide workers with the information they need to use the substance safely.

Figure 2 Example Safety Data Card – adapted from WorkSafe guidance.

What is the problem with labelling of chemicals?

Labelling is often where chemical management systems break down and there is a failure to manage the hazards associated with chemicals .

Businesses occasionally encounter products with incomplete or non-compliant labelling, particularly imported products or products transferred between suppliers. Manufacturers and suppliers are responsible for correctly labelling the products they sell.

Users may also unintentionally obscure labels by how containers are stored or positioned during use.

However, the most common issue arises when chemicals are decanted from their original container into another container.

This typically occurs when:

• Large quantities are transferred into smaller containers.
• Generic spray bottles are used.
• Reusable containers are used for different substances.

In these situations, the original labelling is often lost.

Figure 3 Spot the difference

What are the options for chemical labelling?

When a substance is transferred into another container, responsibility for maintaining appropriate labelling generally falls on the user.

As part of managing the hazards associated with chemicals, products supplied by manufacturers or distributors should already be appropriately labelled. However, when the substance is no longer in the original container, businesses must ensure the necessary hazard information remains available.

Where a substance is decanted into another container and remains under the immediate control of the person using it, full secondary labelling may not always be necessary. However, containers used for storage or shared use should be appropriately labelled.

If a chemical is not in the original container, what should the label contain?

At a minimum:

• Product name or chemical name.
• Relevant hazard pictogram(s).
• Hazard statements.
• Precautionary statements.

For example:

• FLAMMABLE
• KEEP AWAY FROM IGNITION SOURCES
• MAY CAUSE SKIN IRRITATION

Labels that only contain a pictogram provide useful information but may not be fully compliant. Workers may not always understand the pictogram alone, so including written hazard information is recommended.

Figure 4  Labels incorporating text and pictogram

An original label may sometimes be reused where practical and appropriate.

Whilst not reasonably practicable for most businesses, a full label can be manufactured through  https://sdsmanager.com/nz/create-secondary-container-label/.

Figure 5 Fully compliant label

Can I rely on overseas chemical labelling?

Yes.

New Zealand recognises chemical labelling systems from:

• European Union (EU).
• Australia.
• Canada.
• United States.

So are Safety Data Sheets delivering safety?

The objective of SDS is not to accumulate folders of paperwork. It is to deliver safety by providing workers with information to understand the hazards associated with the substances they use and know how to work with them safely.

For most workplaces, effective labelling supported by training and access are the parallel key to chemical safety along with SDS. SDS alone will not deliver chemical safety.

For compliance purposes, business need to retain SDS and they need to be accessible.

Keep SDS in a central, readily accessible repository, maintain compliant labels on all containers, and provide workers with concise safety information they can understand and use – that way you are compliant with the relevant regulations.

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