Is it true that to deal with safety data sheets in a company you must have followed a qualification course and have a UNI certification?
This short article on the SDS manager wants to be a loud reasoning to understand if it is necessary to certify according to UNI / PdR 60: 2019 to carry out professional activities related to the preparation and management of safety data sheets.
The concepts on which the analysis is based are three and they are very simple:
- Some national or European standards require proven professionalism to carry out certain specialized activities. The recognition of professionalism can derive from the type of degree, from well-defined training courses for subjects and hours, from passing exams, from professional qualifications. Examples of figures of this type are the ADR consultant, the PMC workshop technical director, the cosmetic chemical safety assessor, RSPPs and many others.
- The safety data sheet is the document to be drawn up to communicate the dangers that substances and mixtures present and the measures to be implemented to reduce the risks during their use. How, when and why to draw up an SDS is established by the REACH regulation, which also requires that the SDS be drawn up by a competent person , without specifying educational qualifications or professional qualifications necessary to carry out this activity.
[…] The safety data sheet must be completed by a competent person who takes into account the particular needs and knowledge of the users, if known. Suppliers of substances and mixtures must ensure that the competent people have received adequate training including refresher courses. [… ]
- A certification is a procedure by which an independent third party verifies and confirms that a product, service, process or person complies with the requirements specified by a norm .
On the website of UNI (Italian standardization body) we read that
“ […] Reference practices are documents that introduce technical prescriptions or sectoral application models of technical standards, developed on the basis of a rapid sharing process restricted to authors only, under the operational management of UNI, and issued by it, verified the absence of norms or draft norms under study (at national, European or international level). Not being normative documents, the reference practices are not developed within the technical bodies of UNI and the Federated Bodies (which instead have the task of following the competent technical standardization activity relating to the processing of UNI standards, technical specifications and technical reports ) but in special “Tables”.
The reference practices are documents whose contents express the needs of significant market players and whose processing is guaranteed by UNI rules. They are not UNI technical standards, UNI / TS technical specifications or UNI / TR technical reports (from which they differ in the processing process, the types of subjects involved, the level of consent and the graphics) but can become so if they are subsequently shared by the entire reference.”
Starting from these premises, the answer to the starting question is the following:
The management and drafting of safety data sheets in a company must be entrusted to one or more competent persons who are also continuously trained and informed. From a regulatory point of view, there is no standard (understood either as a technical standard, law or regulation) to establish a qualification, training or certification method necessary to officially recognize a professional as a competent person or person in charge of the SDS .
The safety data sheet is a complex document that requires the person who reads it and prepares it to know both the information that must be reported in each of the 16 sections and the regulations on which this same information depends.
Beyond theoretical knowledge, a fundamental starting point for a conscious approach, it is experience that makes the difference in an articulated working context and an area that falls on product safety, the health of workers and consumers and the environmental fate.