The SDS has not changed much with REACH, with the most obvious changes being that sections 2 and 3 have changed over. Of more importance is the expectation that the hazard sections will be based on the robust summaries of substances and that the PNEC and DNEL/DMEL will be included together with vPvB / PBT or CMR assessments. A glossary is provided below.
The SDS is still the ultimate communication tool and writers should be less worried about the format and headings and instead concentrate on communication skills – the SDS must take into account the conclusions of the CSA and the Exposure Scenarios used to write the CSR. The SDS must therefore consider who is reading the SDS and under the conditions of their use.
The key conclusions to the CSR are the proposed Risk Management Measures (RMM) and these needs putting into plain language in the SDS. The ES used to construct the CSR must also be provided in the case of hazardous substances.