ECHA Forum REF-11: What Can We Learn from the EU Analysis of SDS Quality?

The European Chemicals Agency (ECHA) recently published the results of an extensive analysis of the quality of safety data sheets (SDS) across the European Union through its Forum REF-11 project. This analysis provides the most comprehensive insight into the systematic problems that recur in SDS documentation at the European level.

For Serbian companies working with chemicals, the results of the ECHA analysis are more than a mere analysis – they are a practical guide to avoiding the most common mistakes and aligning with EU standards, which is key for exports and safe business operations.

ECHA reveals: 4 systemic problems with SDSs

During the detailed analysis, ECHA inspectors identified four main patterns of problems that recur systematically across different countries, industries and types of companies. This is not a coincidence – these are fundamental challenges that stem from the way companies approach creating and maintaining SDS documentation.

1. Inconsistent approaches to substance classification

The analysis shows that different companies use different approaches to classifying the same substances, which leads to significant uncertainty in practice. This problem arises because there is no sufficiently clear standardised approach to classification, which leaves room for interpretation.

A practical example of this problem can be seen when the same chemical is classified in country A as “Causes skin irritation.” (H315), while in country B the same substance carries the classification “Harmful in contact with skin.” (H312). This difference is not merely semantic – it directly affects the required protective measures and creates confusion among end users.

The cause of this situation lies in the inconsistent application of classification criteria and different interpretation of the available hazard data. Companies often base their classifications on different sources of information or use different methodologies for risk assessment.

2. Outdated regulatory data

The second major problem identified in the analysis concerns the use of outdated regulatory information. This is particularly problematic because regulatory requirements change continuously, and many companies do not track these changes systematically.

A typical case of this problem arises when a company creates an SDS based on the version of the legislation that was current at the time of creation, but over time the legislation was updated with new requirements or changed classifications. The SDS remains unchanged until the problem is noticed during an inspection or an incident occurs.

This problem is especially pronounced in companies that work with a large number of chemicals and have no systematic approach to tracking regulatory changes. Tracking changes manually becomes practically impossible when the portfolio contains hundreds or thousands of products.

3. Missing cross-references

The third problem identified concerns inconsistency between different sections of the SDS. ECHA inspectors noticed that information given in one section is often not consistent with the data in other sections of the same document.

For example, section 2 may state a specific hazard classification, while section 8 does not contain corresponding recommendations for protective equipment that would be adequate for the stated hazard. Or section 3 states a certain composition, while the exposure scenarios in the annex do not take into account all the components listed in the composition.

This problem arises when different sections of the SDS are created independently of one another, or when one part of the document is updated without updating the related sections.

4. Problems with language translation

The fourth systematic problem identified in the analysis concerns the loss of technical precision when translating SDS documents from one language to another. This problem is particularly relevant for Serbian companies, which often have to create SDS documents in several languages.

The problem arises when technical terms are translated literally without sufficient understanding of the context, or when the translator lacks adequate knowledge of chemical terminology. The result can be an incorrect or imprecise transfer of critical safety information.

Why are these findings relevant for Serbian companies?

Experience from my twenty years of practice in the chemical industry confirms that these same patterns of problems regularly appear in Serbian companies as well. The reason the EU analysis is so valuable for us is that it systematically documents and publicly shares its findings, allowing us to learn from the experience of others instead of discovering the same problems independently.

In addition, Serbian companies that export to the EU market must meet the same SDS documentation quality standards that ECHA analyses. Understanding the common mistakes allows us to be proactive in avoiding them.

It is important to note that the problems identified in the EU analysis are not specific to particular industries or company sizes – they appear wherever there is no systematic approach to managing SDS documentation.

A systematic approach as the key to the solution

The most important insight from the ECHA analysis is that most of these problems can be solved by implementing a systematic approach instead of relying on “manual” solutions that are prone to errors and inconsistencies.

Elements of an effective system

Based on the findings of the analysis and practical experience, a systematic approach should include several key components. First, standardised work processes for creating SDSs that ensure a consistent approach to preparing documents across all the staff involved.

Second, the implementation of regular revision cycles that ensure changes in legislation or product composition are reflected in the SDS documentation in a timely manner. This also includes establishing a system for tracking regulatory changes.

Third, cross-checks (cross-check procedures) that ensure consistency between the different sections of the SDS before the document is finalised. This procedure can be manual or automated, but it must be systematic.

Practical benefits of a systematic approach

My experience shows that companies that establish standardised work processes for creating SDSs achieve significantly better results in several key areas.

First, they have fewer problems during updates and revisions because the processes are clearly defined and consistent.

Second, they achieve more consistent quality across all their SDS documents, which improves the credibility and reliability of their documentation.

Third, they can respond more quickly to regulatory changes because they have clearly defined procedures for implementing amendments.

A question to consider

Based on the ECHA findings and local experience, a natural question arises: Do you recognise yourself in any of these problems? Write to us about which part of creating safety data sheets gives you the most headaches.

Conclusion: learning from the experience of others

The ECHA Forum REF-11 analysis is a valuable resource for all of us who work in chemicals management and SDS creation. Instead of discovering the same problems independently through trial and error, we can learn from the systematically documented experience of others.

The key insight is that a systematic approach, combined with an understanding of common problems, can significantly improve the quality and consistency of SDSs. This is not only a question of compliance, but also the basis for a safer working and living environment and more efficient chemicals management.

REF-11 project report

At this link you can find the full ECHA report