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Below is a direct extract from the Safe Work Australia's (SWA) Preparation of safety data sheets for hazardous chemicals - Code of Practice. The red highlighted sections are what many SDS authoring companies are completely ignoring. Some SDS authors that I have consulted referred to the word 'should' as not requiring mandatory compliance but it is only a recommendation.

Structure of hazard statement text

The text in bold in the tables below (Tables of label elements from the GHS) should appear in the SDS, except as otherwise specified. The information in italics should also appear as part of the hazard statement in the SDS when the information is known, for example:

'Causes damage to organs [or state all organs affected, if known] through prolonged or repeated exposure [state route of exposure if it is conclusively proven that no other routes of exposure cause the hazard]'.

The hazard statement codes shown in the tables are intended to be used for reference purposes only. They are not part of the hazard statement text and should not be used to replace it in the SDS.

Structure of precautionary statement text

There are five types of precautionary statements: general, prevention, response (in case of accidental spillage or exposure, emergency response and first aid), storage and disposal.

The core parts of the precautionary statements are shown in bold print. This is the text that should appear in the SDS, except as otherwise specified.

The precautionary statement codes used in the tables below (Tables of label elements from the GHS) are intended to be used for reference purposes only. They are not part of the precautionary statement text and should not be used to replace it in the SDS.

I think authors have forgotten for whom the SDS has been developed. Workers at the coal face have no interested in what the GHS code is, they only want to know 'what are the hazards and precautions' without the clutter of a bunch of meaningless (to them) letters and numbers.

See below an example of a precautionary statements in an SDS from a major supplier of industrial chemicals.

P301+P330+P331 IF SWALLOWED: Rinse mouth. Do NOT induce vomiting.
P303+P361+P353 IF ON SKIN (or hair): Take off immediately all contaminated clothing. Rinse skin with water/shower.
P363 Wash contaminated clothing before re-use.
P304+P340 IF INHALED: Remove person to fresh air and keep comfortable for breathing.
P305+P351+P338 IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing.

We read from left to right and coming across codes before the actual useful information is provided can be confusing and may put the reader off and not continue any further. It may be great for the "techies" of this world to check that the correct statement is used against the corresponding code, however, they are not the users.

For clarity sake, could all SDS authors interpret 'should' as 'shall' and comply with the direction of the Code of Practice.

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