Complying with KKDIK Regulation No. 30105 – Are you prepared for the deadline?
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While safety data sheets (SDS) have become standardized under the Globally Harmonized System (GHS), often they are known to vary in information depending on the regulation and language of a country.
For example, if you are importing a product to the UK, the SDS would be prepared in English. However, if you are importing a product to Spain, the SDS will likely be in Spanish.
Similarly, under the KKDIK, SDS in Turkey are required to be in Turkish. However, this is just one of many conditions SDS must meet to be compliant with KKDIK. Here are the others:
1. SDS must be prepared by a Chemical Assessment Specialist
Chemical Assessment Specialists have to attend a total of 64 hours of training per the provisions of the KKDIK Regulation and this training must be done at a ministerial approved institution.
After sitting for the examinations of the institutions that are accredited by TÜRKAK as per the (TS EN) ISO / IEC 17024 standard, they will be eligible to receive a Certificate of Proficiency which allows a person to write a KKDIK compliant SDS.
2. Chemical Safety Assessment Must be Available
A KKDİK Chemical Safety Assessment is a mandatory requirement for all substances that are manufactured or imported in volumes equal to or greater than 10 tonnes per year and by downstream users if their uses are not addressed by their supplier. A CSA ensures that the risks related to the substance are controlled and is a vital component under KKDİK. This is why it is required to be documented in the chemical safety report (CSR) as part of the registration dossier.
3. Substances must have a registration number
Registration numbers should be specified under title 1.1 for KKDIK compliant SDS for substance and under title 3.2 for the substances which fulfil the requirement of KKDIK registration conditions in the mixture.
When does a KKDIK compliant Safety Data Sheet need to be supplied?
A KKDIK SDS should be provided either before or at the time of first delivery of the substance or mixture if the product is:
a substance or a mixture that is classified as hazardous, or PBT/vPvB or SVHC
a mixture that is not classified as hazardous, but contains a substance posing human health or environmental hazards with a concentration of >1% w/w for non-gaseous mixtures or 0.2% v/v for gases
a mixture that is not classified as hazardous, but contains a substance that is persistent, bioaccumulative and toxic (PBT), or very persistent and very bioaccumulative (vPvB), or substance of very high concern (SVHC) in an individual concentration of ≥ 0.1 % by weight for mixtures that are solid or liquids (non-gaseous mixtures)
Upcoming Deadline
All SDS which are written according to regulation 29204 will be valid until the date of 31st December 2023. After this date, it will be obligatory to write SDS in compliance with Regulation (TC) No 30105.
What's next
Manufacturers, importers, distributors, and downstream users must make sure their current and future SDS for substances and mixtures comply with the KKDİK Regulation to keep their products on the market. Our HazCom experts can help you at any stage of the SDS compliance process. This includes:
Updating current SDS against KKDIK Turkish REACH Regulation requirements
Collection of required data: Full composition data, Physico-chemical information, etc.
Identification of gaps and required changes
Drafting new SDS according to KKDIK Turkish REACH compliant format
Providing necessary recommendations by making a hazard assessment of your substance, mixture or products
Translation into alternative languages as required
Delivery of completed SDS for use and distribution
Get in touch with our team today to get the technical support you need to help you meet these obligations. Also, access the free Yordas webinar library to watch the ‘Turkey SDS according to KKDIK 30105’ webinar, for more insight into the SDS regulations in Turkey.