The Backstory
Unlike the United States, which has no official national emergency response number requirement for its Safety Data Sheets (SDS) regulated under the authority of OSHA, the picture is quite different in the European Union (EU). In the EU, most Member States (MS) have appointed an official emergency response center, whose contact information must be listed in Section 1.4 of the SDS. There are some notable exceptions: Germany, Poland, Italy, and France, for example, have historically had no official national emergency center listed on ECHA’s website.
What’s Changing
While Poland and Italy still do not list an official emergency contact number SDS requirement with ECHA, Germany now notes that manufacturers and importers may optionally notify one of several poison centers in the country, or they may provide their own number, given certain conditions. France now lists the National Research and Safety Institute for the Prevention of Occupational Accidents and Diseases (INRS) as its official emergency contact to be listed in Section 1.4 of the SDS.
Implications
Manufacturers and importers of chemical products and mixtures in the EU must consider specifically which MS their product will be shipped to so that they can in turn list the required national emergency contact of that MS in Section 1.4 of the SDS. Although there are certainly a few notable exceptions, most MS have indeed appointed a single official emergency contact to be listed. If a product is being distributed to numerous MS, then its SDS must either include a complete list of all relevant MS’s official emergency contacts, delineated by MS, or separate documents would need to be created, one for each respective MS. If shipping to dozens of EU MS, or through distributors where this may be a possibility, the required documentation and effort can quickly escalate—SDS authors are wise to consider automated, software-driven solutions to minimize effort and maximize efficiency.
