Strengthening Compliance: Addressing the 4 I’s in Common Safety Data Sheet Compliance Issues
The European Union's intensified focus on enforcing chemical safety regulations, as part of the Chemicals Strategy for Sustainability (CSS), is reshaping how industries must approach compliance. Enforcement remains a critical element of this strategy, with initiatives like the Digital Product Passport and the REACH Regulation highlighting the EU's commitment to transparency and accountability. However, common compliance challenges persist, particularly in ensuring that Safety Data Sheets (SDS) meet legal standards.
Common Non-Compliance Issues in SDS: The 4 I's
Despite the rigorous framework, non-compliance in SDS remains a prevalent issue. This often falls into four categories: Incomplete, Incorrect, Inappropriate, or Inconsistent information. These “4 I’s” are central to many compliance failures, underscoring the need for greater precision in SDS preparation.
Incomplete Information: Missing or insufficient details, such as failure to include hazard classifications, exposure controls, or accurate composition information, create compliance risks. A recent audit found that only 26.4% of SDS were fully compliant, with missing sections being a common issue.
Incorrect Data: Incorrect hazard classifications or inconsistent product identification can lead to misinformed handling, resulting in regulatory penalties. This has been a focus area in the EU’s REACH EN-FORCE (REF11) initiative.
Inappropriate Details: Including irrelevant or excessive information can dilute the critical details, making the SDS less effective as a safety tool. Some SDS misrepresent the chemical’s actual risks or include outdated legislative references.
Inconsistent Reporting: Discrepancies between the SDS and other regulatory documents, such as labelling, can cause confusion for both users and regulators. Consistency is vital in maintaining transparency and trust in the supply chain.
EU's Response and Industry Impact
To tackle these issues, the EU has stepped up enforcement through REF11, focusing on SDS compliance with the updated regulations under (EU) 2020/878. The EU also advocates for harmonised penalties, public identification of non-compliant entities, and revocation of REACH registrations for persistently non-compliant products. This push for greater accountability highlights the serious consequences of not adhering to the required standards.
Looking Forward: Support for Compliance
As the EU strengthens its compliance framework, industries must be proactive in reviewing their SDS to avoid costly penalties. Yordas Group’s audit of over 6,000 SDS revealed that nearly 30% required reclassification. To support businesses in navigating these complexities, Yordas is offering targeted training, such as our 3-Day Hazard Communication Workshop, designed to address the 4 I’s and guide companies toward full regulatory compliance.
With the Digital Product Passport and ongoing enforcement actions shaping the future of chemical safety, the responsibility on manufacturers and importers has never been greater. Ensuring accurate, complete, and consistent SDS information is crucial for meeting the EU’s stringent standards and maintaining market access.
How Can Yordas help?
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About our experts
Fiona Moir
Managing Hazard Communication Consultant
Fiona Moir is the Managing Consultant for Hazard Communication at Yordas Group, responsible for overseeing strategic, commercial, and operational aspects of services such as SDS Manager and Hazard Communication services. With a background in bioscience and over a decade of experience in hazard communication, Fiona excels in setting strategic direction aligned with market needs. She leads product development and commercial management efforts, focusing on revenue growth and expanding Yordas' presence in the EHS sector. Fiona's leadership extends to team development and financial oversight, ensuring robust performance and sustainable business practices. Her expertise in regulatory standards, coupled with strong analytical and communication skills, drives innovation and business success within Yordas Group.
Nathan Town-Field
Senior Hazard Communication Consultant
Nathan Town-Field is a Senior Regulatory Consultant at Yordas, with a focus on global hazard communication. With six years of expertise in GHS and CLP classification and labelling of substances and mixtures, Nathan is well-versed in navigating the complex regulatory landscape surrounding chemical safety. A key responsibility for Nathan leading the team responsible for authoring Safety Data Sheets (SDS) to global standards, ensuring that they accurately communicate the hazards associated with chemicals and provide essential safety information to downstream users. Additionally, he is proficient in poison centre notification obligations, and as Yordas' lead eSDS author, Nathan plays a crucial role in extracting exposure scenarios from various sources.