10/12/2009What does it mean?

We have had a dialogue with the Danish Working Environment Service and the Danish EPA regarding the interpretation of what it exactly means to provide clients with safety data sheets. There is no doubt that it is not sufficient to refer to a web site (www-address).

Is valid in the entire EU

This interpretation is from the REACH regulation and applies in the entire EU!

An extract of the text in REACH says:

The supplier of a substance or a preparation shall provide the recipient of the substance or preparation with a safety data sheet (...)

The supplier shall provide the recipient at his request with a safety data sheet compiled in accordance with Annex II, where a preparation does not meet the criteria for classification as dangerous in accordance with articles 5, 6 and 7 of directive 1999/45/EC (...)

A safety data sheet shall be provided free of charge on paper og electronically.

Suppliers shall update the safety data sheet without delay on the following occations (...)

The new, dated version of the information, identified as 'Revision:(date)', shall be provided free of charge on paper or electronically to all former recipients to whom they have supplied the substance or preparation within the preceeding 12 months.

Any updates following registration shall include the registration number.

Reference to a web site is not enough

It is not sufficient for a supplier to ask his commercial clients to look at the company web site where the client's few products are mixed with the safety data sheets of all other products from the supplier.

It is the duty of the supplier

The purpose of REACH will be lost if the supplier is not required to provide his commercial clients with safety data sheets. In article 35 REACH demands that an employer must make safety data sheets available for this employees but there are no demands in REACH that the employer must obtain safety data sheets from his suppliers as REACH demands that the supplier must provide his commercial clients with safety data sheets.

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