A safety data sheet (SDS) is a document that the supplier of a chemical product provides to describe the hazards of that product and how it can be used safely at work. It is required under chemicals law, and it covers matters such as hazards, handling, storage and emergency measures. When a product reaches the end of its life and becomes waste, its safety data sheet is also one of the sources that official guidance identifies for working out what the waste contains and whether it has hazardous properties.
This article explains what an SDS is, who has to supply one, and how waste classification guidance refers to it. It is written for businesses that use chemical products, from workshops and labs to schools, construction sites and facilities teams.
What a safety data sheet is
The Health and Safety Executive (HSE) describes safety data sheets as important documents in the safe supply, handling and use of chemicals. On its safety data sheets page, HSE explains that an SDS contains the information employers need to carry out a risk assessment under the Control of Substances Hazardous to Health Regulations (COSHH).
An SDS is not a risk assessment in itself. HSE points out that it describes the hazards but cannot take into account the particular workplace in which a product is used. The term MSDS (material safety data sheet) is an older name that is still seen, and HSE's glossary treats the two terms as the same document.
According to HSE, an SDS will typically provide information on:
- the hazardous properties of the substance
- any health effects associated with its use
- how likely it is to get into the air or onto the skin
- handling, storage and emergency measures in case of accident
First aid, spill and handling information for a specific product is found on that product's own safety data sheet. In an emergency, contact the emergency services.
Who must supply a safety data sheet
In Great Britain (England, Scotland and Wales), safety data sheets are required by UK REACH (the Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation). HSE states that an SDS is a must if a chemical is hazardous and is being supplied for use at work, whether in packages or not. One is also needed if a chemical is not classified as hazardous but contains small amounts of a hazardous substance.
HSE's COSHH guidance adds that suppliers must send a data sheet when a product dangerous for supply is first ordered, if the formulation changes, or if the customer asks for one. A business that receives chemicals and then supplies them to others must also pass the information on as safety data sheets. Distributors have the same responsibility to pass safety data sheets down the supply chain.
Defra has lead responsibility for UK REACH and the SDS requirements, and questions about compiling safety data sheets go to the UK REACH Helpdesk.
How the SDS links to classification and labelling
Hazard classification and labelling in Great Britain fall under GB CLP (the Classification, Labelling and Packaging Regulation). HSE explains that GB CLP hazard pictograms are diamond shaped, with a red border and white background, and that one or more may appear on the label of a single chemical.
The SDS and the label work together. The label gives a summary on the container, while the SDS sets out the fuller detail, including the composition of the product and the classification of its ingredients.
Why the safety data sheet matters for waste
Businesses have a legal duty to classify the waste they produce. The Environment Agency's waste classification guidance, known as WM3, sets out the steps. To assess whether a waste has a hazardous property, the producer first needs to know its composition.
WM3 lists the manufacturer's safety data sheet as one source of composition information, where the waste is a manufactured product whose composition has not changed. It also states that if the composition has been altered during storage or use, that information is not to be relied on fully. Other sources it lists include knowledge of a well understood industrial process, and sampling and analysis.
When assessing hazardous properties (numbered HP 1 to HP 15), WM3 describes three methods: calculation against concentration limits, testing, and the safety data sheet for that specific product, again where the composition has not changed. Appendix B of WM3 adds that:
- the chemical classification of the ingredients is listed in the SDS section on composition and information on ingredients
- for a mixture such as a pot of paint, the classifications of the individual component substances are used, rather than the overall classification of the product
- additional checks are needed if the SDS is out of date, or if there is reason to believe it is incomplete, inadequate or inaccurate
- if any action may change the composition or physical form of the product, such as treating the waste, the SDS information is not to be relied on
The GOV.UK page on how to classify different types of waste also refers businesses to manufacturers' product safety data sheets for information on what is in a waste and how much of it is hazardous. It notes that some products, for example cosmetics and medicines, are not normally labelled with hazard symbols.
What hazard pictograms tell you about waste
WM3 notes that products are often labelled with hazard pictograms. If a pictogram is present, a hazardous property is likely to apply. However, the absence of a pictogram does not mean that there are no hazardous properties.
This is one reason the guidance points beyond the label to the safety data sheet and the full assessment steps. For background on what makes waste hazardous, see our guide on what is hazardous waste, and for the wider legal responsibilities, our article on duty of care.
Differences in Northern Ireland
Chemicals law differs in Northern Ireland. HSE states that under the terms of the Northern Ireland Protocol, EU REACH continues to apply in Northern Ireland, and that substances and mixtures placed on the market there are subject to the EU CLP Regulation rather than GB CLP.
WM3 also has separate versions. The GB version is for those who produce, manage or regulate waste in England, Scotland or Wales, while a separate NI version applies in Northern Ireland, where the regulator is the Northern Ireland Environment Agency (NIEA). For more on how the rules vary, see our article on hazardous waste rules across the UK nations.
Related services
Many of the products that come with a safety data sheet end up as hazardous waste streams of their own. Our services include chemical waste disposal, paint disposal and solvent disposal. Classification remains the responsibility of the waste producer, and where a waste falls into a grey area, speak to our team.
Speak to our team
To discuss your waste, contact our team on 0845 366 9306 or email enquire@hazardousdisposal.co.uk.
This article is for general information only and does not constitute professional, legal or chemical advice. Waste producers are legally responsible for correctly classifying their waste. For guidance on your specific waste, please contact our team.