Currently, in accordance with the requirements of the OHS Act, Safety Data Sheets are compiled using information from the EC i.e. CHIP – Chemicals (Hazard Information & Packaging for Supply) regulations & others. This was published by SANS in the form of SANS 10265 but for unknown reasons was never brought into law. Many companies are managing to comply with this with regard to Safety Data Sheets but the labelling requirements in this standard are almost universally ignored.

The issue is further complicated and confused by the fact that the Department of Health uses a classification for Dangerous Goods SANS 10228/9 (transport concept i.e. packages) rather than that used by EC for Hazardous Substances as per SANS 10265 (direct contact). This new proposals at least iron out this confusion as hazardous substances will be defined as those in SANS 10234.

Currently the subject is being muddied by the EC requirements for REACH (Registration, Evaluation and Authorisation of Chemicals) however it must be pointed out that this will only affect the principle raw material suppliers as it relates to substances rather than preparations (mixtures). The information to be supplied will be needed in the preparation of SDSs but the average paint maker could be still faced with the task of extracting the data for up to 1000 substances, quantifying it and compiling the data sheet for some 1000 finished products.

It must be understood that there are two aspects the SDS for the products and within that (Section 15) is the package-labelling requirement for general sale. There are further complexities in differing between basic substances and mixtures. In the EC, where GHS is on the back burner, the present proposal for impementation is 2010 for substances 2015 for mixtures. The data for substances will be supplied by the manufacturers while the compounder has to compile his from an evaluation and calculation of this data.

The GHS being on the back burner will mean that adoption of it here will mean that compounders may have to work with SDSs for imported materials in both formats. If the OHS act insists on GHS then Importers and agents could be required to convert the SDSs for products into the GHS format for local supply. While the apparent change to the GHS appears to be minimal and confined to the ingredients and labelliing sections, all data will need to be verified. It is not clear yet as to whether the EC listings or something similar, which gives cut-off values, will be available. Currently the compilation of a SDS is relatively simple because it uses the Approved Supply Lisring see SANS 10265). As this listing is missing from SANS 10234 the compiler will now have to work from raw data.

A second problem I find is that of the introduction of a new set of safety signs in place of the current ones as per SANS 1186. This could cause major problems for the chemical industrty. It appears to me that these are not an essential component for GHS and could be left to one side for the moment to avoid too many changes at once.

It is found that in the case of complex mixtures, quite common in the paint industry, that a profusion of risk and safety phrase results. I can find no guidelines to the number used and this can mean problems with the smaller containers. I would also suggest that in a third world situation the result is very complex and the leartning curve for the general public and the compiler could be steep.

In my experience the compilation and circulation of SDSs in this country has been very poor and that the smaller companies do not have the facilities or the training to take on GHS at the moment and this will be further complicated by the duplication which is going to be inevitable prospect

I would strongly suggest that SANS 10265 be adopted as the basic rule for this country until such times as GHS has been adopted in the major production centers and experience has been built up. To convert from CHIP to GHS will be easier once experience has been gained by all players.

These comments have been sent to the Dept of Labour. Other organisations are at the same time suggesting that the implementation be postponed until more advanced countries have used it. The latest OCCA Journal Surface Coatings International BCF News Page 346 indicates the approach being taken in the UK.

Any queries do not hesitate to contact me.

Les Fisher

DURBAN 24 January 2008