For example, as part of the Health and Safety Authority’s programme of inspection of REACH and CLP, we assessed 173 SDS for specific products in 2017. The biggest non-compliance relates to occupational exposure limits and control measures which is important to ensuring safer workplaces as it tells the user how much chemical they should be exposed to in a given period or what types of personal protective equipment (PPE) they should wear.

Another area where we see issues is that the information on hazard classification, for example, if the chemical can cause burns, can be missing or incorrect. In this case it is very difficult for the company to adequately assess the hazards associated with the chemical and to best decide how they can reduce the risks for their workers.

For example, if a chemical is identified as irritant when in fact it’s corrosive, this could result in serious burns to eyes or skin. Similarly if the supplier tells the user “wear gloves” but doesn’t specify that a particular type of glove is required, then the chemical could be absorbed through the glove and cause skin irritation or dermatitis.

Secondly, REACH can also support worker safety through the authorisation of substances of high concern. Here the applicant has an onus to demonstrate safe use and identify the appropriate controls. In circumstances where this is found to be lacking, regulators have the power to impose conditions such as additional control measures or monitoring to further protect workers.

However, when conditions are included, they must be done in a manner that is consistent and can be adopted readily into approaches under occupational safety and health. Therefore it is important to have occupational expertise involved in the decision making process.

Thirdly, the recent work of ECHA in assessing the scientific relevance of occupational exposure limits for five carcinogenic substances is a really good example of how co-operation between REACH and OSH can work. My own view is that in order for regulators to regulate appropriately, they first need the right level of scientific assessment and advice.

Much can be gained if the technical expertise in both the REACH and the OSH systems can be made available for each other to an even larger extent. In any event, irrespective of which group provides the scientific advice, it will always feed into the normal decision making process under OSH involving the Advisory Committee on Safety and Health.

In the future, there could be benefit in looking at whether closer alignment is needed on particular types of hazardous chemicals. For example under OSH, carcinogens are covered by the Carcinogens Directive and are also targeted by REACH.

As mentioned above, both regimes are already co-operating on the assessment of exposure limits in workplaces for specific carcinogenic substances. However, chemicals toxic to reproduction or respiratory sensitizers don’t have a specific legislative focus in OSH. A direct focus on chemicals like these might be warranted under OSH, similar to the approach with carcinogens.

In conclusion, the key to safer chemicals and safer workplaces is to communicate information clearly and correctly, whether through the SDS or label or other format that companies provide or whether through regulators regulating their respective areas. There is no point in providing copious amounts of information if the person who receives it puts it in a drawer in their workshop and never looks at it again.

So while there are still challenges out there, I know that if I were to start working in a laboratory today, I would find the information I needed through the SDS and label and that proper training, advice and risk measures would be in place to keep me safe. And if I wanted to know more about a particular chemical, I can always check out ECHA’s dissemination database.

Dr. Sharon McGuinness
Assistant Chief Executive in the Health and Safety Authority in Ireland, Chemicals & Prevention Division and chair of ECHA’s Management board