The Control of Substances Hazardous to Health (COSHH) regulations 2002 require employers to make COSHH assessments. Thus your customers need to think about:
- What do they do that involves hazardous substances?
- How can these cause harm?
- How can they reduce the risk of harm occurring?
They must by law always try to prevent exposure at source. For example:
- Can they avoid using a hazardous substance or use a safer process – preventing exposure, e.g. using water-based rather than solvent-based products, applying by brush rather than spraying?
- Can they substitute it for something safer – e.g. swap an irritant cleaning product for something milder, or using a vacuum cleaner rather than a brush?
- Can they use a safer form, e.g. can you use a solid rather than liquid to avoid splashes or a waxy solid instead of a dry powder to avoid dust?
If they can't prevent exposure, they need to control it adequately by applying the principles of good control practice. Control is adequate when the risk of harm is ‘as low as is reasonably practicable'. This means:
- All control measures are in good working order.
- Exposures are below the Workplace Exposure Limit, where one exists.
- Exposure to substances that cause cancer, asthma or genetic damage is reduced to as low a level as possible
In order to do this they need to look at what products and chemicals they buy in and use . This is where ‘data sheets’ come into the equation. They need enough info about each product they buy to determine if its safe, needs precautions for safe use, or is hazardous and needs special precautions.
By law (REACH) suppliers of chemicals hazardous for use must provide an up to date safety data sheet if a substance is Hazardous for supply using a standard templated layout AKA ‘REACH Safety Data Sheet’.
Customers may additionally ask suppliers of chemicals for a data sheet for a chemical that is not hazardous , to provide evidence from the supplier that it isn’t hazardous to use. Or to detail basic good practice in handling storing and using the product etc. AKA ‘any old chemical safety data sheet’. Or ‘product information sheet’.
Consumers of hazardous products need to have access to standardised safety information.
1. How this affects the fertiliser industry.
a) A safety data sheet (SDS) to the prescribed format must be provided by the producer for every ‘hazardous’ substance or mixture for progression down the supply chain. NB. - ECHA’s Dec 2011 Guidance, recommends a periodic review of the SDS commensurate with the hazards of the product by a competent person. (This is technically a producer responsibility).
2. What format must it take?
a) The data sheet can be supplied as a paper copy or ‘electronically’.
b) A ‘system that merely requires customers to obtain a SDS from a company's website or from
a catalogue of SDS’ is not considered ‘appropriate’ by HSE.
c) A specific ‘link’ to the ‘relevant’ data sheet on a web site in an electronic communication
that was highlighted as the link to the SDS to the customer (e.g. in an invoice ) ought to suffice.
3. Does it need to be supplied each time I make a delivery?
a) No it does not have to be provided each time there is a delivery. Only on the first occasion and each time there is a change in the data sheet.
b) The SDS must however also always be available from you to your customers on demand.
4. I just distribute - do I need to provide my own version of the safety data sheet?
a) Not if you are just supplying someone else’s product- you are expected to pass on their SDS either by hard copy or electronically.
5. What if I blend my own products?
a) If you are purchasing a hazardous (i.e. classified) substance/mixture from a manufacturer or importer, you must demand an SDS from your supplier. This SDS can be passed on (with any necessary amendments) when reselling in the original package or your own
6. Where can I get a generic SDS for the most common blends?
a) AIC together with Fertilisers Europe have produced a suite of standardised SDS’ for the most common products. Which you can copy and personalise.
AIC Generic Product Safety Data Sheets - Fertilisers:
AN Hot Solution Mixture 80-93 percent eSDS Oct 2011 (141kb) Mandatory
CAN below 80 percent AN eSDS Oct 2011 (99kb) Advisory
NPK AN Based 70-80 percent eSDS Oct 2011 (113kb) Mandatory
NPK AN Based below 70 AN NH eSDS Oct 2011 (98kb) Advisory
NPK AN Based below 70 percent AN CLASS 9 eSDS Oct 2011 (95kb) Advisory
NPK AN Based high N 80 percent AN eSDS Oct 2011 (124kb) Mandatory
Straight_ N AN Based Mixture 80 percent AN eSDS Oct 2011 (125kb) Mandatory
Straight_N AN AS Based below 45 percent AN NH eSDS Oct 2011 (95kb) Advisory
Straight_N AN Based Mixture 70-80 percent eSDS 12 Oct 2011 (115kb) Mandatory
Straight_N AN Substance Oct 2011 (117kb) Mandatory
7. I don’t know what is classified or what isn’t.
a) Ask your supplier(s) for a list of hazardous REACH/CLP classified products that they supply you and an SDS for each such product.
b) Identify these on your inventory system.
c) If you are producing blends, you must determine from the ingredients you use which are
hazardous ones, and ensure that you provide a relevant SDS for each product containing them to your customers.( See detailed checklist – Appendix 1 below)
8. AIC used to have data sheets for a lot of ‘other’ products
a) They aren’t required under REACH as most products aren’t hazardous but are ‘advisory information’ sheets only.
9. What don’t I need to provide a data sheet for?
a) You do not need to provide a SDS if the substances/mixtures are supplied in the UK and not classified as hazardous. (See checklist below Appendix 1).