If we are shipping to foreign countries, can we just use the US SDS?
Posted: Tue Dec 17, 2024 6:08 am
On the SDS, do only chemicals with hazardous conditions need to be listed? For example, what if you have a product that is 95% non-hazardous and the other 5% is confidential, does the manufacturer need to list that confidential ingredient if it has a hazardous condition? The
hazards of the confidential ingredient must be listed in Section 3. See OSHA’s interpretive letter here for more information.
The SDS also has emergency and technical telephone numbers (Section 1). Can the CHEMTREC telephone number be used in either case (domestic or global)? I was told that CHEMTREC can only be used on the shipping paper.
Emergency number on SDS: If you subscribe to CHEMTREC’s ERIP service, you can include CHEMTREC’s emergency number(s) in Section 1 of the SDS.
Technical or non-emergency numbers: CHEMTREC’s emergency number(s) should not be displayed as a technical or non-emergency number. If you require additional support outside of Emergency Response, please contact [email protected] .
Domestic or global: CHEMTREC has a set of domestic emergency numbers to band database support regulatory emergency number requirements and languages worldwide. The emergency number to be displayed for national, regional or global audiences may differ. Please contact CHEMTREC if you need assistance selecting the correct CHEMTREC emergency number.
It is the responsibility of the foreign country importer to provide an SDS for that jurisdiction (as well as language requirements).
Does OSHA plan to require manufacturers to begin providing SDSs for hazardous materials or substances contained in an article?
CHEMTREC cannot speak for OSHA or their plans to require SDSs, but OSHA did not propose any changes to the definition of articles in its recent Proposal. It should be noted that downstream users were aware of/have requested them. If you would like to hear more about CHEMTREC authorizing your article SDSs, please email [email protected] or complete our online form.
If a product is manufactured in the EU and sold through a distributor in the US Does the distributor offering the product provide the required US SDS?
The US importer is responsible for providing a compliant SDS to the US. Please click here to view the OSHA LOI for “responsible party.”
If company X sells a product to company Y, does the responsibility for SDS requirements transfer to company Y? For example, if company Y moves the product to another country, who is responsible for generating the compliant SDS for that country?
The foreign country importer is responsible for providing the SDS for that jurisdiction (as well as any language requirements).
Are there specific wording requirements for Section 2 Hazard Statements?
For specific wording requirements, see Appendix C to 1910.1200- Label Element Allocation here .
Will you be hosting a webinar on what is required in the upcoming HCS revisions?
We are considering hosting a webinar to provide more information about the upcoming HCS revisions. Keep an eye out in your email inbox for more information!
hazards of the confidential ingredient must be listed in Section 3. See OSHA’s interpretive letter here for more information.
The SDS also has emergency and technical telephone numbers (Section 1). Can the CHEMTREC telephone number be used in either case (domestic or global)? I was told that CHEMTREC can only be used on the shipping paper.
Emergency number on SDS: If you subscribe to CHEMTREC’s ERIP service, you can include CHEMTREC’s emergency number(s) in Section 1 of the SDS.
Technical or non-emergency numbers: CHEMTREC’s emergency number(s) should not be displayed as a technical or non-emergency number. If you require additional support outside of Emergency Response, please contact [email protected] .
Domestic or global: CHEMTREC has a set of domestic emergency numbers to band database support regulatory emergency number requirements and languages worldwide. The emergency number to be displayed for national, regional or global audiences may differ. Please contact CHEMTREC if you need assistance selecting the correct CHEMTREC emergency number.
It is the responsibility of the foreign country importer to provide an SDS for that jurisdiction (as well as language requirements).
Does OSHA plan to require manufacturers to begin providing SDSs for hazardous materials or substances contained in an article?
CHEMTREC cannot speak for OSHA or their plans to require SDSs, but OSHA did not propose any changes to the definition of articles in its recent Proposal. It should be noted that downstream users were aware of/have requested them. If you would like to hear more about CHEMTREC authorizing your article SDSs, please email [email protected] or complete our online form.
If a product is manufactured in the EU and sold through a distributor in the US Does the distributor offering the product provide the required US SDS?
The US importer is responsible for providing a compliant SDS to the US. Please click here to view the OSHA LOI for “responsible party.”
If company X sells a product to company Y, does the responsibility for SDS requirements transfer to company Y? For example, if company Y moves the product to another country, who is responsible for generating the compliant SDS for that country?
The foreign country importer is responsible for providing the SDS for that jurisdiction (as well as any language requirements).
Are there specific wording requirements for Section 2 Hazard Statements?
For specific wording requirements, see Appendix C to 1910.1200- Label Element Allocation here .
Will you be hosting a webinar on what is required in the upcoming HCS revisions?
We are considering hosting a webinar to provide more information about the upcoming HCS revisions. Keep an eye out in your email inbox for more information!