SDS Section 1 (Tab "1 Identification")

Quick start

In this section, you establish the basic identity of your product: Names, identification codes, product uses, contact information, and emergency telephone number(s).

Þ Fields and other items that are “required” — recommended to generate a substantially complete SDS — have burgundy titles or applicability notes on the entry form.[1]

Þ For general guidance, refer to the Managing help box, below.

1. Name — Enter the name of the product. The name is required to save the SDS record.

2. Product no. and Brand (2 fields, optional) — Enter if relevant.

3. UFI (required for EU/EEA[2]) — Enter the Unique Formula Identifier (UFI).

You generate the UFI yourself on the ECHA Poison Centres website.

Input:

a. Your company's Value-Added Tax Identification Number (VATIN); and

b. A company-internal formulation code that you assign to the product (a number between zero and 268,435,255).

If you don't have a VATIN, or want to keep your VATIN confidential, use the "Get a company key" tab on the website’s UFI generator link to obtain a company identification number, prior to generating the UFI itself.

You can generate more than one UFI for the same mixture (e.g., for different product packaging styles or for marketing in different countries), but the mixture composition must always be the same.

UFI numbers enable poison control centers in the EU to provide advice to customers in an emergency. Therefore, you must also prepare and submit a matching Poison Centre Notification (PCN) with the necessary information about the product, using the ECHA submission portal.

4. This product contains nanoforms (check box, required for EU/EEA if nanoform particles are present) — Check this box to place the statement, “Nanoform: This product contains nanoforms” into this section. “Nanoform” is an EU regulatory term for substances containing one or more sets of particles in the 1 to 100-nm range (nanoparticles), where the sets share certain physical-chemical characteristics.

5. Other means of identification (optional; may be required for Canada, EU/EEA, and GB) — Enter alternative names, trade names, or codes commonly used for the product.

You may want to include descriptions aiding in identification (product/package appearance, container type(s), etc.).

Don't re-enter the product name, or names/codes that you have entered elsewhere (e.g., CAS, EC, REACH numbers). The list of items in this field should not be long.

6. Recommended use of the chemical and restrictions on use — Explain in simple terms the most common uses for the product. If more detail is needed, make reference to SDS Section 16, and place the details there. For EU/EEA and GB SDSs, include anticipated uses of the product. Avoid vague statements like "all legal uses". If relevant, identify inappropriate uses of the product.

7. Show more (button, to display optional items) — If your product is a substance (rather than a mixture); or if you plan to make a claim of Confidential Business Information (CBI) in Canada; then click on the Show more button:

“Show more” button.

a. For a substance, enter the CAS number where available, or the Chemical name. You will be linking the SDS to a record in the Substances section, and the program may ask whether it should copy information from the Substance record onto the SDS. If a Substance record doesn't exist, you'll be asked to create one.

b. For a Confidential Business Information (CBI) claim in Canadian markets, enter the HMIRA RN (registration number) and Claim filed (date). If Health Canada granted the claim, enter the Granted (date). (For CBI claim requirements, read the discussion under “HMIRA RN” in the details section, below.)

8. Mfr./Supplier — Enter manufacturer, importer, distributor, or other responsible party name and address. Click on the Mfr./Supplier button to copy either your address in Preferences or an address from the Suppliers section of the program.

9. National contact in another country (required in the EU/EEA when the supplier is not located in the Member State where the product is placed on the market) — Enter the name and contact information for a designated Responsible Person in the destination EU Member State for the product. Click on the Contact button to copy either your address from Preferences, or an address from the Suppliers section of the program.

10. Emergency telephone number(s) — Enter one or more emergency telephone numbers, including the hours of service. Identify any limitations on the type of information that the emergency service can provide. The European Chemicals Agency (ECHA) maintains a list of emergency telephone numbers for EU countries.

11. Next, click on the “3 Composition” tab.

Managing help

· If this help window opened automatically when you started the program, then you have automatic help turned on. To change automatic help, click on the “Auto-help is” on/off pushbutton, on this window.

· When automatic help is off, you can display or refresh this help window manually, by using the [Ctrl]-9 shortcut (“Background for this section”).[3]

· To get an overview:

o Take the Brief tour on how the SDS entry form works:

§ Entering SDS content

§ Navigating the form

§ Shortcuts and convenience features

§ Translation features

§ Generating the SDS and GHS labels

To start the tour, click on the Help button and select “Brief tour”.

o Watch the video on this tab (click on the Video button, if the label is in blue text).

o Read the “Features common to most SDS form sections/tabs” section, below.

· For brief tips, hover with your mouse over the object of interest.

· To get assistance on a particular field: Click into the field, then click on the Help button, and select “Guide this item” (shortcut: [Ctrl]-5).

· To get stepwise assistance for all areas on this tab: Click on the Help button and select “Guide this section” (shortcut: [Ctrl]-6).

· To learn additional details and requirements, including guidance from regulatory agencies (US-OSHA, UN, EU, and Health Canada), read the details section, starting immediately below.

SDS Section 1 (Tab "1 Identification") – details

I. Features common to most SDS entry form sections/tabs

Adding content to the SDS

Character limits on text fields

Dates and numbers

Recommended entry areas

Preformatted entry

Layering of windows and the mouse pointer

Using the <tab> markup symbol (optional)

Multi-language fields

Multi-language fields in tables

Non-English SDS or label generation

Country-specific language requirements

Alternate language selection

Other (non-supported) languages

Translation

Zoom (button and menu, magnifying glass icon, adjacent to the field)

Template (check box, top right)

Using templates

Archive (check box, top right)

Paste (button, top right)

Link (button, top right)

Entry form tables

Tables occur in four locations on the SDS entry form:

These tables do not all work in exactly the same way. In general, however:

Indicators and controls (located along the bottom of the SDS form)

Progress indicator (double green bars)

Autosave (active/inactive status indicator)

[N]o data (button)

Stoc[k] (button)

Display mode (button)

Zoom (button in Edit/display grouping)

Spel[l] (button)

Navigation controls

"Tabs" (left arrow button, drop-down menu, and right arrow button)

“SDSs” (first, previous, next, and last buttons)

Build options (located along the bottom of the SDS form)

“Build” (SDS and Label buttons)

Help resources (located along the bottom of the SDS form)

Help (button)

Video (button)

Research (drop-down menu)

Interim Save-Done-Cancel (buttons)

Interim save (button with disk icon)

Done (button)

Cancel (button)

II. Instructions for Section 1

Name (required to save record)

SDS description (unlabeled field, to the right of the Name field)

Alternate language (drop-down menu)

Template

I. Features common to most SDS entry form sections/tabs

Note: Additional information is also available on common features by taking the tour (Help button -> "Brief tour").

SDS data entry form (Tab "1 Identification").

Adding content to the SDS

Areas where you can enter information on the SDS form include:

· Text-type (alphanumeric) fields of single-line height

· Text-type fields with multiple-line height ("multi-line" fields)

· Cells within spreadsheet-style tables (beige-and-white columns)

· Drop-down menus with no direct entry

· Drop-down menus with direct entry ("combo boxes")

· Date, time, and numeric fields

Most entry areas on the SDS form are multi-line fields, permitting paragraph-style content, including carriage returns. Single-line text fields generally do not accept carriage returns.

Multi-line field.

Character limits on text fields

Some single-line fields are limited to a maximum input of 255 characters. Multi-line fields typically accept an unlimited number of characters.

You can determine the number of characters that a text-type field supports by clicking on its “Zoom” button (where available), a magnifying glass icon just to right of the field:

"Zoom" (button adjacent to a field).

This action causes the program to display a separate zoom dialog for editing the field contents.

A red message appearing at lower left on the zoom dialog indicates the number of characters entered, the total number of characters allowed, and if carriage returns are permitted. If no red message appears, field capacity is essentially unlimited, and carriage returns are allowed.

Zoom dialog for a text-type field.

Dates and numbers

Single-line boxes can also represent dates or numbers. For a date, the program will generally accept the “local” date format. For example the US date format would be “mm/dd/yyyy”, whereas other countries might use “dd/mm/yyyy”. For numbers, you can generally enter only numeric characters (an exception is "E", for an exponent, where "2.5E3" indicates "2500").

Recommended entry areas

Fields, table cells or other areas on the SDS entry form that are “required” — recommended to generate a substantially complete SDS — generally have labels in burgundy text. For example, an SDS should have a manufacturer/supplier name and address (Mfr./Supplier), and Emergency telephone numbers(s). Entry of information into these areas is "required" only for completeness of the generated SDS; it is not necessary to save the SDS record.

An exception for SDS entry is the product Name field. Content in this field is necessary to save an SDS record. Without a Name entry, the [S]ave and Done (disk icon) buttons will be disabled.

Preformatted entry

Almost all text entry is freeform; you enter the text and any punctuation (slashes, periods, etc.) relevant to the field. For example, on a date you can use slashes, periods, or hyphens to separate the month, date, and year values.

In a very limited number of cases, the form limits you to particular characters as you enter them (an "entry filter"). For example, when entering a UFI code, the field restricts you to entering 16 alphanumeric digits (no slashes, periods, or hyphens), and converts lowercase letters to uppercase as you type.

Layering of windows and the mouse pointer

Normally the mouse pointer is the standard pointing arrow, and it will become a vertical bar when you click into a field or table cell. Occasionally you may see a mouse pointer that looks like a pair of overlapping rectangles:

Mouse pointer indicating the active window is behind the frontmost window.

In this case, the "active" window (where the program is expecting data entry or other user activity) is layered behind another window. The active window might be a zoom dialog, a translation dialog, or a confirmation dialog (requesting a response). Use the keystroke [Ctrl]-z to restore the active window as the front-most window.

Using the <tab> markup symbol (optional)

Some multi-line fields support the use of a <tab> markup symbol within the text, as an option. The <tab> markers allow you to create up to three columns of information when generating an SDS on the Build report or Build report NE form tabs.

For example, the following three lines could be used to create a two-column "mini-table" of values within a field:

Type<tab>LD50<tab>Date
Oral<tab>3.1 mg/kg<tab>3/15/1998
Dermal<tab>0.4 mg/kg<tab>4/9/1980

...would yield on the generated SDS:

Type        LD50        Date
Oral        3.1 mg/kg   3/15/1998
Dermal      0.4 mg/kg   4/9/1980

By default, the tabs for most fields are at 2, 3.5, and 5 inches. You can change their locations, or add more tabs, by editing the associated style sheet in the SDS word processing areas, on the "Build SDS" and "Build SDS non-English" form tabs. (SDScribe™ generates the full SDS in word processing areas on these tabs.)

Multi-language fields

SDScribe™ is capable of generating safety data sheets and GHS labels in languages other than English. The program makes use of multi-language fields for this purpose. Multi-language fields:

· Store both the English-language content and the equivalent non-English ("counterpart") content.

· Are actually pairs of fields, one for the English-language text (white background), and the other for non-English text (beige background).

· Are layered over each other, so that displaying one (e.g., selecting “Show English” from the field’s Zoom button) will hide the other (non-English).

· Can also be displayed in many cases with both the English and non-English text visible in a split view, by selecting “Show both” from the field’s Zoom button.

Multi-language field for inhalation, on the "4.1 First aid" tab, showing the English field.

Multi-language field for inhalation, split view (“Show both”).

Multi-language fields in tables

Multi-language fields can also appear as column pairs in spreadsheet-style tables, on the SDS entry form. The non-English text is normally in a column to the right of the companion English-language text, and the non-English column title includes the phrase “click translate”. Clicking on this column title while the row is highlighted provides a mechanism for translating from the English. Both columns should be visible by scrolling the table horizontally.

Multi-language field for the hazard classification description, “2 Hazards” tab. The “Description” column contains the English text, and the “Description (click translate)” column contains the non-English text.

Non-English SDS or label generation

When you’re ready to generate the SDS or a GHS-type label, the program uses either the English-language field content or the non-English field content, depending on what you select from the “Build” controls at the bottom of the form.

Build label button, bottom of SDS entry form. The non-English language that is available here comes from your choice in the Alternate language drop-down menu (top right on the form).

At SDS generation time, the program will also include section titles and GHS hazard classifications[4] in supported languages (refer to Alternate language selection, below).

To generate the full SDS and/or to generate GHS labels in a supported[5] non-English language, you will need a supplemental license. You enter the supplemental license number using the Options button in Preferences (File menu -> Preferences). If you don't have a supplemental license, the program will still accept entry into foreign-language fields. However, it will generate only a portion of the non-English SDS, as a demonstration.

For details on supplemental licensing, email Hazard Solutions. To purchase the license, go to the SDScribe™ web site.

Country-specific language requirements

In the US, OSHA requires safety data sheets in English. However, you might also provide a non-English SDS if your workers or your customers’ workers speak a native language other than English.

Health Canada requires Canadian SDSs to be in both English and French, and GHS labels should be bilingual (the “Bilingual” format is available when you select label generation options in the program). Other countries generally require SDSs in their official language(s).

China (PRC) requires Simplified Chinese, but chemical identification must be in both Simplified Chinese and English.

The United Nations Economic Commission for Europe (UNECE) has compiled GHS implementation requirements for selected countries and regions, which includes notes about required languages. You can access the requirements by clicking on the GHS version label/link, at top left on the “2 Hazards” tab in the program, or click here. The nature of information of this sort is that it quickly becomes outdated, so it’s wise to double-check, paying particular attention to the revision date of the source.

Alternate language selection

An Alternate language drop-down menu at the top right on the entry form enables you to select the intended language for a non-English SDS, and for non-English labels.

Whether or not you have selected a non-English language in the drop-down menu, you can still generate an English-language SDS from the “Build SDS” (English-language) tab.

Language selection drop-down menu.

The languages listed in the menu have ISO-standard, two-letter codes. A trailing asterisk (*) on the language code indicates that it is supported: translated SDS titles, subtitles, and GHS classifications are available as internal program resources.

Supported languages currently include:

o French

o Italian

o Korean

o Portuguese

o Simplified Chinese

o Spanish

Other (non-supported) languages

Selecting a target language without an asterisk may result in generating an SDS or a label that still has English field labels and/or hazard classifications.

However, you can supply the necessary information to support any language listed, by creating your own custom translation group (CTG). From the File menu, select “Phrase translations”, and then click on the “Custom translation groups (CTGs)” tab. Click on the Help button on the form, and read the directions there.

Generating a non-supported, non-English-language SDS in full does not require an additional SDScribe™ license. Polish is included gratis as an example of a CTG, and you are free to generate a full SDS in Polish.

Creating a custom translation group (CTG) for a non-supported language, in the Phrase translations section of the program.

Translation

Translation support is available by selecting "Translate" from the Zoom button pop-up menu, to the right of a multi-language field. This menu item opens the translation dialog.

Translation dialog.

As the translation dialog opens, your web browser should open as well, to the Google Translate web site. If so, move the browser window over to the side, so it does not obscure the translation dialog.

The English content from the multi-language field (“Text from the English-language field, to be translated”) appears just below a set of directions (“Directions for translation”). In addition, the program has placed the English content onto the computer's clipboard.

For illustration, a display-only picture of the Google Translate web site is located in the middle of the dialog ("Sample only, edit in your web browser window"). However, it also has an embedded web link, so that if for some reason your web browser did not open with the translation dialog, you can click on the picture to open it.

At the bottom of the dialog is a box for the translated text, which you paste into the box after translation is complete on the web page (“Translated text, copied from the right-hand box in Google Translate (paste here)”). Click on the OK button to copy the translated text back onto the SDS entry form.

Detailed directions for translation appear at the top of the translation dialog itself (“Directions for translation”).

NOTE: You can use Google Translate or any other web page that provides translation services. You can also copy and paste directly to and from the web browser into the SDScribe™ field; you are not required to use the Translation dialog.

Zoom (button and menu, magnifying glass icon, adjacent to the field)

Zoom button for a multi-language field.

To view and/or edit the content of text-type fields more easily in a larger area, you can click on this button, just to the right of each field. For fields that support only English-language entry, clicking the zoom button presents the zoom dialog for editing the English field contents. A picture of such a zoom dialog appears above (Zoom dialog for a text-type field).

For multi-language fields, the program displays a pop-up menu:

· Show English – normal display mode, showing the English-language field with a white background.

· Show non-English – alternate display mode, showing the counterpart field for non-English data entry. A non-English field has a light beige background color, and usually occupies the same area on the entry form as its English-language equivalent.

· Show both – displays both the English-language field and the non-English language field in a side-by-side (split) format. Applies to most (but not all) multi-language fields.

· Zoom English – displays the English-language field in a larger area in a separate window (the zoom dialog), so that the contents are easier to view and to edit. Clicking the OK button on the zoom dialog places the edited content back into the English-language field, on the SDS entry form.

· Zoom non-English – displays the counterpart, non-English language field in the zoom dialog, so that the contents are easier to view and to edit. Clicking the OK button places the edited content back into the non-English field, on the SDS entry form.

· Translate – copies the English text to the clipboard, and opens the translation dialog (discussed above).

· Autospell this area on – Turns on word processor-style markings for potentially misspelled words, when the cursor is inserted into the field.

· Autospell this area off – Turns off the autospell markings for the field.

There is also a more general Zoom button at the bottom of the form. It displays the zoom dialog for the field in which the cursor is located.

Template (check box, top right)

Checking this box enables you to convert an SDS record into an SDS template record. The program displays a conversion dialog, with options to either convert the current SDS record into a template (Convert SDS to a template button); or to make a copy of the record, and then designate the copy as the template (Duplicate SDS as a template button).

The dialog includes check boxes for deleting content from specific sections of the SDS that may not be appropriate to include in the template. For example, a template probably won't include specific chemical names, identification numbers, components, etc.: You would probably want to check the "Sect. 1/ Identifiers: chem. name, prod. nbr…" box and the "Sect.3/ Common names, impurities, …" box.

Conversion dialog, for creating a template from an SDS.

You can also create an SDS template directly from the SDS browse list. Highlight an SDS row, click on the [D]uplicate button (the double-square icon) and select “Duplicate as template” from the pop-up menu. Or you can right-click directly on an SDS row, and select “Make template from SDS” from the contextual menu.

Selecting the “Duplicate as template” option to create a template in the browse list. The row representing the SDS must be highlighted first.

Selecting “Make template from SDS” after right-clicking on an SDS, to create a template in the browse list.

Using templates

SDS templates are "sourdough starters" for safety data sheets that contain basic information intended for a class of products. Templates can save you time if you manufacture or market a range of products for which the hazards, first aid, firefighting, and other SDS sections are likely to be similar across the products. For example, you might call a template “Cleaner, liquid, caustic” if you market several caustic liquid cleaners that have similar base formulations.

When you create a new SDS from the browse list, the pop-up menu on the [N]ew SDS button allows you to select a template (“New SDS from template”). The program then displays a dialog listing available templates; selecting one of them creates a clone of the template for you to complete. The template itself remains unchanged.

SDScribe™ includes sample templates for cleaning products, dyes, floor strippers, paint, and personal care products (among others). The SDS entry form for a template has a yellow background, whereas a normal SDS entry form has a beige background.

Some fields in the sample templates include choices that you would make based on product characteristics. For example, a field may contain instructions to use some but not all of the included text.

Sample of instructions in a field, on an SDS template.
(The field contents appear here in the "zoom" dialog for purposes of illustration.)

In the illustration, you would follow the instructions to use particular text, eliminating the other text and the instructions themselves. Instructions appear between double slashes ("// ----- instructions ----- //"). You might also enter other information that is relevant to your specific product.

For additional discussion of templates, refer to the “SDS Templates” section of the SDScribe™ FAQs.

Archive (check box, top right)

Checking this box causes the program to designate the SDS as archived, meaning that it will appear in the browse list when you select “Archived” from the All [J] button pop-up options. (You can also right-click directly from the browse list to designate one or more SDSs as archived.)

[A]ll button menu on the browse list. Select “Archived” to display archived SDSs.

Archived items will also appear after browse list searches, either using the quick search box or the [F]ind button.

Quick search and [F]ind button, browse list.

Paste (button, top right)

This button allows you to insert relevant content for the SDS that may be available from:

1. An existing SDS template, for the same field or fields on the current tab; or

2. The corresponding field or fields of a linked Substance record, for one or more components of the product.

Not all fields in an SDS record have an exact equivalent in a Substance record, so on some tabs the Paste button is not available. In a few cases, the information from the component records may only be of general value. You may still need to customize the content you paste to suit your needs.

Paste button and dialog. Items of type “Component” appear in the Component table, on the “3 Composition” tab of the SDS.

Clicking on the button displays a dialog for adding content to multi-line text fields. You can select from available templates or, for a product that is a mixture, items from mixture components (i.e., ingredients).

There are options to insert content into:

· The field where the cursor is located; or

· All fields in the current form tab; or

· All relevant sections of the SDS .

The program can also either append the new text after existing field content, or entirely replace the existing content.

Paste button options (after selecting from the pop-up menu).

After pasting text either from a template or from a Substance record, the new text will appear in the target field(s) after a separator line similar to:

//----- Pasted into field: "Stab incompat materials" from template: "Irritant liquid template" on 6/21/2017, 12:38 pm ----- //

You can then remove this line as you continue to edit field content.

Link (button, top right)

Link button, showing pop-up menu of actions.

When clicked, this button displays a pop-up menu of available actions, for either linking to or displaying existing records in the Substances section of the program, representing the SDS product itself or its listed ingredients.

· Show Substance linked to this SDS – Display the Substance record linked to the SDS product itself. The Substance record will appear in a separate window.

If a link doesn’t already exist, the program may offer to create one. (Not all SDSs have a linked Substance record. The ones that have a link typically represent single-constituent products.)

· Clear Substance link to this SDS – Removes an existing link between the SDS and a Substance record.

· Link SDS to an existing Substance – Attempts to link a Substance record to the SDS, based on the product's CAS no. or Substance name (both fields are on the “1 Identification” tab of the SDS, when the Show more button is depressed). If both fields are empty, the program will display a list of all Substance records.

Dialog for linking an SDS to a Substance record. Once you select a row, the program may offer to copy properties from the Substance record over to the SDS.

· Create new Substance linked to this SDS – Creates a new Substance record based upon the SDS. Includes components (ingredients), hazards, physical properties, and other parameters from the SDS.

· List all components – Displays a list of SDS components in the Substances section. Displays an error message if the product has no components.

· Show Substance for selected component – Displays a list of SDS components, from which you can select one for display in the Substances section of the program. Displays an error message if the product has no components.

A frame around the Link button, along with a name change to "Linked", indicates that a link already exists from the SDS to a corresponding Substance record.

Entry form tables

A table (or list) on an entry form is similar to a spreadsheet. If a table cell is editable, you can use the mouse to click into the cell to change its contents.

Component table, on "3 Composition" tab.

Tables occur in four locations on the SDS entry form:

· "1 Hazards" tab (Hazard table)

· "3 Composition" tab (Component table)

· "8.1 Exposure-protection" tab (Exposure limits table)

· "15.1 Regulatory" tab (Regulations table)

These tables do not all work in exactly the same way. In general, however:

· Click into the cell in a row that you want to edit.

· If you are upgrading from a previous version of SDScribe™, you may need to perform a slow, repeat click (a "slow click", as before), to enter a cell for editing. For new users, a single click on an editable cell should allow you to edit the cell. You can switch between these two "click edit" settings for tables, in Preferences:

Setting "single-click" mode in Preferences. Single click is the default setting for the current version of SDScribe™.

· Use the [Tab] key, or click out of (away from) the cell for the changes to "register". (You still need to save the SDS record itself, using the [S]ave or Done button to preserve the changes; if you click on Cancel to close the SDS entry form, the record will revert to its state at the last time that you saved it.)

· Cells located in columns with a beige-and-white color scheme are editable, while cells in gray-and-white columns are for display only, and are not editable.

· If you want to select a row, click with the mouse onto a gray-and-white (display-only) column for that row. If you click onto a beige-and-white (color) column, then with the single-click setting in Preferences, you will likely click into the cell immediately below the mouse pointer. Clicking into the cell may not select the entire row.

· To select more than one row, [Shift]-click if the added row(s) are adjacent to the first row; or [Ctrl]-click to add any other row, whether adjacent or not.

· Column headers are not editable. However:

o Headers that are underlined feature one or more special actions, such as re-ordering table rows; displaying a pop-up menu of actions; or performing a translation into another language. Some of these functions require you to first highlight the row you want to change.

o Headers in boldface burgundy text indicate items that are recommended to generate a substantially complete SDS.

· Some tables perform special functions if you right click on a row.

· Click on the trash can icon to delete one or more selected rows in the table. (The Hazard table displays a pop-up menu of special options, when you click on the trash can..)

Indicators and controls (located along the bottom of the SDS form)

Lower edge of the SDS entry form.

Progress indicator (double green bars)

The progress indicator provides a general estimate of fields and/or other items throughout the SDS entry form that have been completed. The incomplete (blank) area to the right of the green bar represents “action items” — items that may be needed to complete the SDS. Action items may also include certain types of errors, warnings, and/or inconsistencies. As you address the action items, the green bars will move further to the right.

· In the upper bar, the green portion represents the number of visible items completed, as a portion of all visible items.

· In the lower bar, the green portion represents the number of visible, “recommended” items completed, as a portion of all visible required items. “Recommended” in this context means items that are needed to prepare a substantially complete safety data sheet.

When the "NE lang" button is depressed, so that the non-English language fields are being displayed, the thermometer bars will change to reflect the fact that a different selection of fields are now visible.

Similarly, clicking on the “Show more” pushbutton on the “1 Identification” tab; or the “Substance” radio button on the “3 Composition” tab, will change the fields that are visible, and reset the bar positions.

A frame around the thermometer indicates that certain types of action items are present, such as errors, warnings, or required items.

If you click on the progress indicator, the program will display a searchable dialog of action items. Double clicking on a row in the list will take you to the location of the field or other item.

“Action items” dialog, listing individual required items, errors, warnings, and optional items.

No SDS is likely to have information entered into all fields, and some of the available fields may be more relevant to certain types of SDS formats than to others. However, the green thermometer should give you some idea of how far along you are, in assembling the information for the SDS.

Autosave (active/inactive status indicator)

The italicized text below the progress indicator displays the status of automatic saving (Autosave). Autosave can be activated by going to File -> Preferences, and setting the interval to some value other than zero minutes.

Autosave interval (located in Preferences)

For example, if you select 4 minutes as the interval, then the indicator will display “Autosave every 4 minutes”. While the entry form is open, the program will briefly display a “Saving…” message on four-minute intervals, indicating that the record is being saved. If an item required to save the SDS is missing (currently the product name), then autosave cannot occur.

[N]o data (button)

Clicking this button places "No data available" into one or more fields on the current tab of the entry form. Most areas on an SDS should not be empty[6], so this phrase substitutes when more informative content is unavailable.

The button displays a pop-up menu of options,

“No data” button, showing pop-up menu.

· Current location – The program inserts “No data available” at the current location of the cursor (the text-type field into which you last clicked with the mouse).

· Empty locations this tab – The program inserts “No data available” into all relevant, empty text-type fields on the current tab. If a relevant field already contains text, then the program will not replace it.

· All locations this tab – The program inserts “No data available” into all relevant, text-type fields on the current tab, whether empty or not.

If you hold down the [Alt] key while selecting one of these options, the program will prompt you for a custom expression to insert in the target fields. You must keep the key held down until after you select the menu option.

Option to select the phrase to be inserted, for the [N]o data button.

Stoc[k] (button)

Displays the stock phrases dialog, a scrolling table of expressions that may be helpful for adding content to text-type fields. From this dialog, you can select one or more phrases to be inserted into the current location of the cursor (the text-type field on the SDS, into which you clicked with the mouse). For phrase insertion to be successful, the cursor must be located in the SDS entry form field, before clicking on the Stoc[k] button.[7]

Common phrases tab

Initially, the dialog displays common phrases that are relevant to (associated with) the current location; the Current radio button is selected, and the name of the current location (SDS field) appears just to the right of the Current button.

However, you can click on the Any radio button to display all available stock phrases (for any location).

Stock phrases dialog, "Common phrases" tab.

Precautionary statements tab

A "Precautionary statements" tab is also available, for inserting one or more precautionary (P-) statements into the current location. In this case, the Current radio button will obtain all precautionary (P-) statements that are associated with the SDS record itself, instead of with the current location.

Stock phrases dialog, "Precautionary statements" tab.

Inserting stock phrase(s) into the current location on the SDS entry form

Click to select (highlight) the first row you wish to paste into the current location. Then [Shift]-click to select additional rows that are adjacent to each other. Or [Ctrl]-click to select additional rows (whether adjacent or not). Then click on the Pas[t]e selected phrases button to insert the phrase(s) back into the SDS, at the current location of the cursor.

Inserting stock phrase(s) into cells of an SDS entry form table

Stock phrase insertion is generally not available for cells in tables. However, there are some exceptions:

· The Exposure limits table on Tab “8.1 Exposure-Protection” (“Basis/monitoring/notes” English and non-English columns)

· The Regulations table on Tab “15.1 Regulatory” ("Regulation…" and "Applicability" columns)

Click with the mouse into the cell in which you want to insert a stock phrase, click on the Stoc[k] button, and follow the same steps as for insertion into a field.

Stock phrases editing controls

These items are located beneath a "mini tab", at lower right on the table, in the "Show editing options" tab. They apply only to the "Common phrases" tab of the stock phrases dialog; precautionary (P-) statements cannot be edited here.

You cannot add, delete, import, or edit items on the Common phrases tab until you click on the "Show editing options" mini tab. Gray-and-white columns in the table are for display only, and cannot be edited.

Stock phrases dialog, editing controls.

Delete

Delete one or more selected (highlighted) phrases from the table.

Export, import, or print

The [E]xport/Import/Print button includes three options in a pop-up menu:

· Export to spreadsheet — Export the listed stock phrases as a comma-separated (.csv), 6-column text file, suitable for use with spreadsheet programs.

· Import from spreadsheet — Import a comma-separated text file (.csv) or a tab-delimited text file (.txt) on disk. The import should detect the format of the text file (.csv or .txt); and whether the file has two, four, or six columns. The four- and six-column imports are capable of updating existing stock phrases, while the two-column file will only add new stock phrases. For additional details on the import, select "Import" from button pop-up menu, and print the instructions.

· Quick report — Print the listed stock phrases, using a report template. The program includes example templates, but also allows you to create your own using the Quick Report editor.

Add the product name to an existing stock phrase

To add the product name to an existing row as an example where the stock phrase is used, highlight the row and then click on the Add example where used button. This function works only if there is a current location of the mouse, for pasting into the entry form.

Add a stock phrase

With the [N]ew phrase button, you can add your own entry to the common phrases dialog. The entry will be associated with the current location of the cursor on the SDS form; the product name will appear in the “Examples where used” column of the common phrases table. If the current location on the SDS already contains text, then the program will offer to copy that text from the SDS into the new stock phrase.

Rollback and the stock phrases dialog

Revisions you have made to an SDS record are protected by a rollback feature, whereby clicking on the Cancel button returns the SDS record to its condition at the time you last clicked on the [S]ave button. (If you haven't used the [S]ave button since opening the SDS record, then the record will return to its condition when you opened the SDS form.)

This discussion of stock phrases assumes that you opened stock phrases from the SDS entry form, using the Stoc[k] button. Under these circumstances, if you click on the Cancel button on the SDS entry form, any edits, additions, and deletions that you may have made to stock phrases will also "roll back" to their condition when the SDS record was last saved. For this reason, ensure that you click on the [S]ave or Done button after you close the stock phrases dialog and return to the SDS entry form.

To alert you of the possibility of a rollback, the stock phrases dialog presents a warning across the top,

Changes to stock phrases will be saved ONLY if you save the underlying form with which you are working.

Exception: If you import stock phrases, the program will run the import in a separate, "protected" process, so the phrases added during the import will remain, even if you cancel the underlying SDS entry form.

Display mode (button)

You can switch between viewing English, non-English, or both (split view) for most multi-language fields using this button, in the “Edit/display” controls at the bottom of the form. The button will change its label from “English” to “Non-Eng” or “Both”, depending upon what you select.

This button setting also affects which evaluations the program performs for generating action items, and for the progress indicator position: If you select “Non-English” or “Both”, the program will evaluate the non-English field content in multi-language fields, whereas the “English” setting will trigger evaluation of the English content.

The display mode button setting does not affect the visibility of multi-language fields in tables.

Display mode button, for switching the view of most multi-language fields. Selecting “Non-English” or “Both” also causes the program to evaluate the non-English field content instead of the English field content, for the progress indicator and action items.

Zoom (button in Edit/display grouping)

This button works in similar fashion to the Zoom button with the magnifying glass icon (the one next to most multi-line text fields, as discussed earlier). It displays field text in a larger area. Click with your mouse into the field, and then click on this button. You can use the [Ctrl]-[Shift]-Z keyboard shortcut for convenience.

Spel[l] (button)

Click this button when the cursor is in a text-type field, to check the field contents for spelling errors. You can also activate or disable background spelling correction for all fields. This feature does not work in table cells, unless you first display their contents in the zoom dialog.

The button displays a pop-up menu of spelling options.

Spel[l] button pop-up menu.

Spel[l] button pop-up menu, for selecting a spelling option.

· Check spelling current location – The program actively checks the contents of the current location. It displays a spelling correction dialog if it finds possible errors. If you see a brief message ("Checking spelling...") appear on the screen, but the correction dialog does not appear, then the spell check did not detect any errors.

The spelling correction dialog does not have a Cancel button. If you wish to dismiss it before the spelling check completes, use the [Esc] keystroke.

· Autospell on – By default, this option is turned on. The program checks all text-type fields in background mode, using red underlining to highlight possible errors. This action is similar to how a word processor handles potential misspellings.

· Autospell off – Turns automatic spelling off for all text-type fields.

· Select dictionary – If you are spell-checking a non-English location or locations, select a dictionary for the program to use. Presently the program includes dictionaries for English, Spanish, French, and Portuguese.

Selecting a spell-checking dictionary.

Navigation controls

"Tabs" (left arrow button, drop-down menu, and right arrow button)

The left and right arrow buttons navigate from one tab to another on the entry form. Each tab represents one SDS section or a partial SDS section, except for final ones after the "16 Other" tab: these are for generating the SDS, generating labels, and for miscellaneous notes. When the left arrow reaches the first tab, it will then “wrap around” to the last tab if you click on the left arrow again. Similarly, the right arrow will wrap around to the first tab, if you click on it again.

The drop-down menu between the left and right arrow buttons lists all tabs by name, so that you can select one directly, without moving through the other tabs to arrive on the tab that you want. You can use the [Ctrl]-[Shift]-T shortcut to display the tab menu.

“SDSs” (first, previous, next, and last buttons)

These buttons move from one SDS record to another. For example, if you wish to go to the previous record, you would click on the left single (“<”) arrow button.

Normally these buttons save your work before moving on to another record. However, if there is a problem that prevents the current SDS record from being saved, the program will present a warning, asking whether you wish to move on without saving the record.

Navigating to another SDS record when the current one cannot be saved. In this case, the product name is missing (upper left).

Build options (located along the bottom of the SDS form)

“Build” (SDS and Label buttons)

The SDS and Label buttons generate an English SDS; a non-English SDS; a GHS label; or an FDA label. The program automatically moves to the appropriate tab. If the program detects that there are entry areas without content, or there are other issues, it will notify the user, and offer the option to continue despite the potential issues.

Notification that items may need to be addressed (prior to SDS or label generation).

Clicking on the Show Items button will dismiss the dialog (without generating the SDS or GHS label), and display the action items dialog. Thus, you can address the missing items or problems, and then click on the SDS or Label button again.

If you have previously generated an SDS or a GHS label, or otherwise placed text in the location for the generated SDS or label (these locations are individual word processing areas), then the program will ask whether it should generate the SDS or label anyway, discarding the existing text.

If you elect to proceed, the program presents a generation options dialog, for either an SDS or a label. For information on the options, refer to the Help menu, "Background information for this section" on the appropriate SDS form tab.

SDS generation options dialog.

GHS label generation options dialog.

Help resources (located along the bottom of the SDS form)

Help (button)

This button contains a pop-menu of help items for providing assistance in completing the entry form.

Help button pop-up menu.

· Brief tour – Displays a small, green window identifying features of the SDS entry form. Useful if you want to familiarize yourself with the SDS form but do not wish to read through the background information presented here.

· Resume tour – If you closed the tour window but wish to resume, click into the field or area where you left off, and select this item.

· Guide from beginning – Displays a small, yellow window explaining the purpose of individual fields and other items on the SDS entry form, as they relate to completing an SDS. Guides you through the entry form tabs in an order that allows you to have adequate information at hand to complete the next section(s).

· Resume guide – If you closed the guide window but wish to resume, click into the field or area where you last left off and select this option.

· Guide this item – Select this item to view information about the field or area in which the cursor is currently located.

· Guide this section – Select this item to view all guide information for the current tab on the SDS entry form.

· Change guide settings – Displays a dialog with a list of preferences for how the guide operates. You will also see this dialog when you start the guide from the beginning.

Set guide settings window.

If you are a new user of SDScribe™, then you may want to click on “All available assistance”, so you are able to understand the functions of each field or area, whether or not they presently have contents.

· Show hazards this SDS – Displays a separate window listing GHS hazard classification, hazard (H-) statements, precautionary (P-) statements, and pictograms from the “2 Hazards” tab of the SDS entry form. Having this list open may be useful for reference, if you are working in a different tab.

“Show hazards this SDS” window.

· Background information for this section – Displays detailed help for the current tab on the SDS entry form. This document (which you are now reading) is the background information for the “1 Identification” tab.

Video (button)

This button has blue text and a blue surround when an instructional video is available. Videos are located on the SDScribe™ YouTube channel, so you must have Internet access to watch them.

Research (drop-down menu)

This menu contains Internet links that may be relevant in researching your product or its components. Selecting a menu item will open your web browser to the requested site.

Because web managers periodically change the internet addresses (URLs) of items on their sites, some of these links may no longer work. In this situation, you may want to perform a Google-type search for the site at its new address.

For some destinations, the program can insert the CAS number, EC number, or chemical name of the SDS product (or one of its components) into the site URL; this action should result in the site opening to a chemical representing the SDS or one of its components. In other cases, the program can place the CAS number, EC number, or chemical name on the computer clipboard, so that you can right-click to paste it into a search box on the web page.

The Research menu also includes listings for SDScribe™ resources: frequently asked questions (FAQ) and a YouTube channel.

Research (drop-down menu).

Some entry form tabs also have a separate button that has a subset of the full Research menu, relevant to the particular tab.

SDS entry form, “8.1 Exposure-protection” tab, showing the additional Research button pop-up menu. This menu contains a subset of the items in the full Research button menu that relate to exposure limits.

Interim Save-Done-Cancel (buttons)

Interim save (button with disk icon)

Clicking on this button allows you to save your work on the SDS up to the current point, without closing the entry form. It’s similar to the “Autosave” feature discussed earlier, except that you instigate the save manually.

Once you have clicked on this button, clicking on the Cancel button will no longer return the SDS to the original condition when you first opened it. Instead, it will return to the condition when you last clicked on Interim save, or when the program last saved the SDS record automatically.

Done (button)

Clicking here saves your work on the SDS, and returns to the browse list. You do not need to click on the Interim save button first, before clicking on the Done button; either one performs the same task of saving the SDS record.

Cancel (button)

Clicking here closes the SDS entry form and returns to the browse list, without saving any information that you may have entered since the last time you opened the form, or the last time you clicked on the Interim save button.

II. Instructions for Section 1

Fields and other items that are recommended to generate a substantially complete SDS[8] have burgundy labels.

SDS “1 Identification” tab, without the “Show more” button engaged.

Name (required to save record)

This field is at top left on the form. It contains the name of the product for which you are creating the SDS. It will appear at the top of the generated SDS, and on labels. Generally, it is a brand name, chemical name, common name, generic name, or trade name.

When creating a new SDS, the Done button at lower right will be disabled until you enter a name here, and then click or [Tab] away from the field.

If you are creating an SDS template instead of a product SDS, then this field could contain a brief description of its applicability. For example:

Template: Carpet and fabric cleaner, liquid: poss. irritant, non-flam.

This example indicates the product usage, physical form, and potential health risks in an abbreviated format.

SDS description (unlabeled field, to the right of the Name field)

Optionally enter information describing the SDS itself, like an internal description or revision information. If you are creating multiple copies of the same SDS for different languages, you could include the name of the language or destination country here. For example: "PT-750-H France", "PT-750-H Italy", "PT-750-H Brazil", etc.

This information does not appear on the generated SDS. For revision/update information that does appear on the generated SDS, refer to Tab “16 Other”, near the bottom of the form (e.g., the fields “Version”, “Revision”, “Supersedes”, “Issued on”, and “Print date”).

Alternate language (drop-down menu)

Refer to the earlier discussion, under Alternate language selection.

Template

Refer to the earlier discussion, under Template (check box, top right).

Product no.

Enter a catalog number, SKU, or other number for the product, if applicable.

Brand

If you market the product under a specific brand, enter the brand name here.

SDS no.

If you serialize your safety data sheets, you can optionally enter an alphanumeric code here. Clicking on the button to the left of the field will cause the program to enter a randomized set of digits.

Product contains nanoforms (EU/EEA requirement)

Checking this box causes the program to insert the following statement into the generated SDS, as a part of the product identifier:

Nanoform: This product contains nanoforms.

Annex VI of the EU REACH regulations defines a nanoform as

“...a form of a natural or manufactured substance containing particles, in an unbound state or as an aggregate or as an agglomerate and where, for 50 % or more of the particles in the number size distribution, one or more external dimensions is in the size range 1 nm-100 nm, including also by derogation fullerenes, graphene flakes and single wall carbon nanotubes with one or more external dimensions below 1 nm.”

The updated instructions for compiling SDSs in Regulation (EU) No. 2020/878 indicate that

“If the safety data sheet pertains to one or more nanoforms, or substances that include nanoforms, this shall be indicated by using the word ‘nanoform’.”

Annex VI of REACH includes comprehensive guidance for characterizing nanoforms. For the purposes of this section (product identification), however, we recommend that you check this box if:

1. The product or its components contain particles with at least one external dimension in the 1-100 nm size range (“nanomaterials”); and

2. You are distributing the product in the EU/EEA.

UFI (EU/EEA requirement)

Enter the Unique Formula Identifier (UFI) that you have generated for this product.

The UFI is part of an EU/EEA requirement to provide information on GHS-classified products to European poison control centers. The UFI requirements went into effect on 1 Jan 2021 for consumer and professional products, and will go into effect on 1 Jan 2024 for industrial products.

The UFI is a 16-digit, alphanumeric serial number that you generate on the ECHA Poison Centres website. To generate the UFI, you will need a value-added tax identification number (VATIN), plus a company-internal formulation code that you assign to the product (a number between zero and 268,435,255).

If you don't have a VATIN, or want to keep your VATIN confidential, the website can instead issue a company identification number. Use the "Get a company key" tab on the website to obtain this number, prior to generating the UFI.

You can generate more than one UFI for the same mixture (e.g., for different product packaging styles or for marketing in different countries), but the mixture composition must always be the same.

You must also prepare and submit a matching Poison Centre Notification (PCN) for the product, using the ECHA submissions portal. This information assists poison centers in responding to emergency calls, where knowing the product contents may be crucial.

The UFI must appear in a conspicuous location on product labels. If you distribute the product in bulk rather than in packaging, then the UFI must appear in the first section of the SDS.

If you have entered a UFI, the program will include it both on the generated SDS and on generated GHS labels ("GHS label" tab).

UK post-Brexit

The UK does not use the UFI system,[9] and there is at present no requirement to for product suppliers to submit notifications to UK-based poison control centers. However, you can submit safety data sheets on a voluntary basis, by emailing them to the National Poisons Information Service (NPIS, product notification), sds.npis@nhs.net.

Once the NPIS has acknowledged your submission, you may want to add the UK National Health Service (NHS) 24-hour urgent care advice line (“111”) to the Emergency telephone number(s) field. It should not replace the supplier’s emergency telephone contact number, however.

Other means of ident. (or use alt. title) (two entry areas)

The small box immediately to the right of this label enables you to re-name this field on the generated SDS. If this box is empty, then the field name on the generated SDS will default to “Other means of identification”. Click on the adjacent “Zoom” button to enter the field name in a non-English language.

For the main box below the field title, enter descriptive names for the product, other than what you have already entered as the product name (above).

If you are distributing the product in a country/region which requires product registration, or which assigns other types of identifiers for which the program does not have a dedicated field, then you may want to add those identifiers here.

There are already dedicated identification fields for CAS number, EC number, Index number, REACH registration number, and HMIRA registration number, so you should not repeat these identifiers here.[10]

Recommended use of the chemical and restrictions on use

Indicate the most common uses for the product, using relatively short, simple descriptions. For example, you might list the common uses as bullet points.

Avoid vague statements like “any legitimate use” or “any legal purpose”, because these impart no real understanding of product use.

If there are additional, less common uses or if you want to discuss product usage in more detail, then you could refer the reader to additional details in Section 16 (the “16 Other” tab on the entry form).

If there are uses that should be avoided, then you should identify those as well. Some regulatory authorities may require an explanation of why the use(s) should be avoided.

From the UN GHS 7th Revised Edition:

“Provide the recommended or intended use of the substance or mixture, including a brief description of what it actually does, e.g., flame retardant, anti-oxidant, etc. Restrictions on use should, as far as possible, be stated including non-statutory recommendations by the supplier.”

From Regulation (EU) No. 2020/878:

“At least a brief description of the identified uses (for example, floor cleaning, or industrial use in polymer production, or professional use in cleaning agents) relevant for the recipient(s) of the substance or mixture shall be indicated.”

“The uses which the supplier advises against and the reasons why shall, where applicable, be stated. This need not be an exhaustive list.”

“Where a chemical safety report is required, the information in this subsection of the safety data sheet shall be consistent with the identified uses in the chemical safety report and the exposure scenarios from the chemical safety report set out in the annex to the safety data sheet.”

Show more (pushbutton, upper right)

Depress this button to display optional fields that may be relevant to the product. To reduce confusion and to save space, these fields do not appear by default on a new SDS. However, the fields will appear by default on an existing SDS if any of the fields have content.

Fields with “double-dagger” annotated labels (‡) relate to claims of Confidential Business Information (CBI) under Canadian regulations.

SDS entry, “1 Identification” tab, with the “Show more” button pressed.

Product Safety Data Sheet (PSDS) (“Show more” button is depressed)

Check this box if your product is a manufactured article rather than a substance or a mixture. The program will change the title of the generated document from “Safety Data Sheet” to “Product Safety Data Sheet”.

Product safety data sheets leverage the SDS format for communicating potential hazards in manufactured goods to distributors, customers, and other downstream users. They are an option rather than a regulatory requirement.

Under US-OSHA regulations (29 CFR 1910.1200(c)), an article:

“…means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical (as determined under paragraph (d) of this section), and does not pose a physical hazard or health risk to employees.”

US-OSHA exempts articles from SDS requirements. However, some jurisdictions may require notification to downstream handlers and users for articles containing hazardous substances above certain concentration levels. Where exposures are possible, a product safety data sheet may be a suitable option to advise users of safe handling and storage practices.

First page disclaimer for PSDS (“Show more” button is depressed)

If you checked the PSDS box (above), text that you enter here will appear at the top of the first page, below the product name. You can use it as a general disclaimer; for example, a statement that indicates that the recipient assumes responsibility for the correct use of the product. Consult a legal professional for exact wording of the disclaimer.

CAS (“Show more” button is depressed)

Enter a Chemical Abstracts Service (CAS) Registry number, if your product has one. Typically, substances-type products rather than mixtures have CAS numbers, although there are exceptions.

After you enter a CAS number, the program will attempt to link the number with a record in the Substances section of the program. If no record exists, the program will prompt you to create a new Substance record. If you cancel the request, the program will then remove the CAS number.

If a corresponding Substance record is found, the program will prompt you to select information from the Substance record that you want copied onto the SDS.[11] [12]

Selecting information from a matching Substance record, to be copied onto the SDS form.

Subs. name (“Show more” button is depressed)

Enter a chemical name for the substance corresponding to your product. If your product is a mixture, then in most cases you can skip this item.

If you have a substance-type product and have already entered a CAS number (above), then there may be a name in this location already. If so, in most cases you can skip to the next entry item.

If you were not able to find a CAS number for a substance-type product, however, try entering a chemical name (or the first part of the name) here, and then [Tab] or click away from the field.

The program will try to link the SDS to a Substance record, in similar fashion to the linking that would have taken place with a CAS number. If the program finds more than one Substance record matching the name or partial name you entered, it will display a list of these records, from which you can select the correct one.

As previously noted, if you have already entered an Index number for the product, and the product distribution includes the EU/EEA, then you should also use the substance name as it appears in Annex VI table of harmonised entries of the EU CLP regulations.

CAS number vs. Substance name linking

When you enter a CAS number, the program will always attempt to establish a link to a Substance record. If you remove or replace the CAS number, the program will break the existing Substance record link and (in the case of a replacement) establish a different Substance link. You cannot have a CAS number entered without also having a Substance record link

In contrast, the Substance name field affords some leeway: You can change the name without breaking an existing link. For example, you might manually change the name from "Strontium chloride" to “Strontium chloride (anhydrous)”. The program will ask if you wish to link to a different Substance record (or add a new Substance record), but you are not required to do so.

This behavior is also useful if you want to use a name on the SDS which is not the main name shown on the Substance record; for example, the name you want to use on the SDS might be listed as a synonym on the Substance record.

Copying over/removing supplemental information

As noted with the CAS number field, after the program has linked the SDS to a particular Substance record, it may present options to copy information from the Substance record onto the SDS. You probably will want to obtain this information.

However, if you want to change an existing Substance link by entering a different name here, then first remove any supplemental information that came over from the previous Substance record, like physical properties, fire hazards, etc. The program will not remove these items automatically.

EC (“Show more” button is depressed)

Enter a European Community inventory (EC inventory) number, if available. Typically, pure substances rather than mixtures have EC numbers.

The EC numbers are a combination of three older inventory lists, all with the same basic format: “xxx-xxx-r”, where “x” and “r” represent numeric digits, and the “r” is a checksum digit to verify accuracy of the other digits. The first “x” value indicates the older (source) list.

· “2xx-xxx-r” and “3xx-xxx-r” — EINECS (European Inventory of Existing Commercial Chemical Substances)

· “4xx-xxx-r” — ELINCS (European List of Notified Chemical Substances)

· “5xx-xxx-r” — NLP (No-Longer Polymers)

Many substances that have CAS numbers do not have EC numbers. Unlike entering a CAS number, entering an EC number will not instigate a search for a matching Substance record.

Index (“Show more” button is depressed. Required for EU/EEA if listed.)

If your product is listed in Annex VI table of harmonised entries of the EU CLP regulations, then enter the number from the first column of the table here. If it is listed, then for the EU/EEA you must also enter the chemical name/description as it appears in the table, into the Name field.

Skip this entry if your product is not listed, or if you aren’t distributing the product in the EU/EEA.

REACH: EU (“Show more” button is depressed. Required for EU/EEA if registered.)

If your product is a registered substance in the EU/EEA, then enter the REACH registration number.[13]

The European Chemicals Agency (ECHA) issues 18-digit REACH registration numbers to companies manufacturing or importing more than one metric ton of product in/into the European Union. Possession of a “final” REACH registration number indicates that the company has successfully completed the chemical registration process. (Final numbers have a “01-“ prefix.)

A company that is located within the EU must apply to the ECHA by submitting a registration dossier for the product. When ECHA accepts the application, it will issue the final REACH registration number

A company located outside of the EU cannot submit the registration dossier. In this case, a representative for the company that is located within the EU submits the dossier.

When including the REACH number on an SDS, you can hide the last four digits to preserve confidentiality (e.g., “01-0000589787-41-xxxx”, where the “xxxx” are the hidden digits).

REACH: UK (“Show more” button is depressed. Required for GB if registered.)

If your product is a registered substance under UK REACH, then enter the UK REACH registration number. UK REACH is the post-Brexit equivalent of its EU/EEA counterpart, for chemicals produced in or imported into England, Scotland, and/or Wales, in quantities over one metric ton per year.

The UK Health and Safety Executive agency administers UK REACH, and issues the 18-digit registration numbers.

HMIRA RN (“Show more” button is depressed)

Enter the HMIRA registration number here, if you have one.

If you have made a claim of confidential business information (CBI) under the Canadian Hazardous Materials Information Review Act (HMIRA), and Health Canada has deemed your application to be complete, it will assign an HMIRA registration number, along with the claim filing date.

CBI that can be withheld for Canada includes the specific chemical names of trade-secret ingredients, and/or the actual concentration or actual concentration ranges of the ingredients in the product.

For more information on CBI claims under the HMIRA, consult the Health Canada guidance on CBI exemptions, or search in your browser for “HMIRA registration number”.

A 2018 amendment to the Canadian Hazardous Products Act now permits the use of prescribed concentration ranges (rather than actual concentration ranges) for ingredients, without going through the HMIRA application process. If you choose this method, and do not also plan to withhold the specific chemical names of one or more ingredients, then you won’t need to file a claim under HMIRA. In this case, you would leave this field and the associated filing and approval dates empty.

Claim filed (“Show more” button is depressed)

Enter the date on which Health Canada deemed your HMIRA claim to be complete, and issued an HMIRA registration number.

Granted (“Show more” button is depressed)

Enter the date on which Health Canada granted your request to withhold confidential business information, under the HMIRA process.

Supplier (tab with multiple fields; Mfr./Supplier button)

Identify the manufacturer, importer, or other responsible party for the product, including address and other contact information.

If you created the SDS by clicking on the [N]ew SDS button (browse list) and selecting “New blank SDS” from the pop-up menu, then the program may have already inserted a default address. The default is either:

A Supplier record for which you checked the box, “Use this supplier as the default for a new SDS (Section 1)"; OR
Your default address in Preferences.

The Mfr./Supplier button pop-up menu allows you to select an address from program preferences (your address), or from the Suppliers section of the program. You can also create a new Suppliers section record with an address entered manually here.

Address button pop-up menu, Supplier tab on the “1 Identification” tab of the SDS.

Supplier entry form, check box for designating a default supplier
(“Use this supplier as the default for a new SDS (Section 1).

Logo (not labeled)

The Supplier tab also includes an optional, rectangular area for pasting in a logo from the clipboard. If present, the logo will appear on generated SDSs and GHS labels.

The program supports most bitmap graphic formats (gif, jpg, png, tiff) and certain others like SVG, although the others may not be viewable until the SDS or label is generated.

National contact in another country (tab with multiple fields, Contact button)

Some regulatory agencies require a manufacturer located outside the borders of a country to provide an in-country contact. For a manufacturer/supplier in the EU, the national contact is the Responsible Person you have designated in a different Member State (the destination for the product). Click on the Contact button to copy over either your address in Preferences or an address from the Suppliers section of the program.

Emergency telephone number(s)

Enter telephone numbers, language(s) spoken, and hours of operation. This field holds paragraph text, so the information can be placed on multiple lines as necessary for clarity.

III. US-OSHA guidance for completing SDS Section 1

From: “OSHA Brief: Hazard Communication Standard: Safety Data Sheets”, https://www.osha.gov/Publications/OSHA3514.html.

Section 1: Identification

This section identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier. The required information consists of:

· Product identifier used on the label and any other common names or synonyms by which the substance is known.

· Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number.

· Recommended use of the chemical (e.g., a brief description of what it actually does, such as flame retardant) and any restrictions on use (including recommendations given by the supplier).

IV. UN guidance for completing SDS Section 1

From "Globally Harmonized System of Classification and Labelling of Chemicals (GHS)", 7th Ed., by Secretariat, United Nations Economic Commission for Europe (UNECE). ©2017, United Nations. Reprinted with the permission of the United Nations.

A4.3.1: Identification

Identify the substance or mixture and provide the name of the supplier, recommended uses and the contact detail information of the supplier including an emergency contact in this section.

A4.3.1.1 GHS Product identifier

The identity of the substance or mixture (GHS product identifier) should be exactly as found on the label. If one generic SDS is used to cover several minor variants of a substance or mixture, all names and variants should be listed on the SDS or the SDS should clearly delineate the range of substances included.

A4.3.1.2 Other means of identification

In addition, or as an alternative, to the GHS product identifier, the substance or mixture may be identified by alternative names, numbers, company product codes, or other unique identifiers. Provide other names or synonyms by which the substance or mixture is labelled or commonly known, if applicable.

A4.3.1.3 Recommended use of the chemical and restrictions on use

Provide the recommended or intended use of the substance or mixture, including a brief description of what it actually does, e.g. flame retardant, anti-oxidant, etc. Restrictions on use should, as far as possible, be stated including non-statutory recommendations by the supplier.

A4.3.1.4 Supplier’s details

The name, full address and phone number(s) of the supplier should be included on the SDS.

A4.3.1.5 Emergency phone number

References to emergency information services should be included in all SDS. If any restrictions apply, such as hours of operation (e.g. Monday - Friday, 8:00 a.m. - 6:00 p.m., or 24 hours) or limits on specific types of information (e.g., medical emergencies, or transportation emergencies), this should be clearly stated.

V. European Union guidance for completing SDS Section 1

From: “COMMISSION REGULATION (EU) 2020/878 of 18 June 2020, amending Annex II to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)”. Official Journal of the European Union, 26.6.2020.

NOTE: Regulation (EC) No. 1272/2008 (referenced herein) incorporated the GHS system into the EU hazardous material regulatory framework.

For further guidance on the compilation of safety data sheets, refer to the handbook: "Guidance on the compilation of safety data sheets", Version 4.0, European Chemicals Agency (ECHA), December 2020. ©2020, European Chemicals Agency.

SECTION 1: Identification of the substance/mixture and of the company/undertaking

This section of the safety data sheet shall prescribe how the substance or mixture shall be identified and how the identified relevant uses, the name of the supplier of the substance or mixture and the contact detail information of the supplier of the substance or mixture, including an emergency contact, shall be provided in the safety data sheet.

Product identifier

The product identifier shall be provided in accordance with Article 18(2) of Regulation (EC) No 1272/2008 in the case of a substance and in accordance with Article 18(3)(a) of Regulation (EC) No 1272/2008 in the case of a mixture, and as provided on the label in the official language(s) of the Member State(s) where the substance or mixture is placed on the market, unless the Member State(s) concerned provide(s) otherwise.

For substances subject to registration, the product identifier shall be consistent with that provided in the registration and the registration number assigned under Article 20(3) of this Regulation shall also be indicated. Additional identifiers may be provided even if they have not been used in the registration.

Without affecting the obligations of downstream users laid down in Article 39 of this Regulation, the part of the registration number referring to the individual registrant of a joint submission may be omitted by a supplier who is a distributor or a downstream user provided that:

(a) this supplier assumes the responsibility to provide the full registration number upon request for enforcement purposes or, if the full registration number is not available to him, to forward the request to his supplier, in line with point (b); and

(b) this supplier provides the full registration number to the Member State authority responsible for enforcement (the enforcement authority) within 7 days upon request, received either directly from the enforcement authority or forwarded by his recipient, or, if the full registration number is not available to him, this supplier shall forward the request to his supplier within 7 days upon request and at the same time inform the enforcement authority thereof.

A single safety data sheet may be provided to cover more than one substance or mixture where the information in that safety data sheet fulfills the requirements of this Annex for each of those substances or mixtures.

Where different forms of a substance are covered by one safety data sheet, relevant information shall be included, clearly indicating which information is related to which form. Alternatively, a separate safety data sheet may be prepared per form or group of forms.

If the safety data sheet pertains to one or more nanoforms, or substances that include nanoforms, this shall be indicated by using the word “nanoform”.

Other means of identification

Other names or synonyms by which the substance or mixture is labelled or commonly known may be provided.

Where a mixture has a unique formula identifier (UFI) in accordance with section 5 of Part A of Annex VIII to Regulation (EC) No 1272/2008 and that UFI is indicated in the safety data sheet, then the UFI shall be provided in this subsection.

Relevant identified uses of the substance or mixture and uses advised against

At least a brief description of the identified uses (for example, floor cleaning, or industrial use in polymer production, or professional use in cleaning agents) relevant for the recipient(s) of the substance or mixture shall be indicated.

The uses which the supplier advises against and the reasons why shall, where applicable, be stated. This need not be an exhaustive list.

Where a chemical safety report is required, the information in this subsection of the safety data sheet shall be consistent with the identified uses in the chemical safety report and the exposure scenarios from the chemical safety report set out in the annex to the safety data sheet.

Details of the supplier of the safety data sheet

The supplier of the safety data sheet, whether it is the manufacturer, importer, only representative, downstream user or distributor, shall be identified. The full address and telephone number of the supplier shall be given as well as an email address for a competent person responsible for the safety data sheet.

In addition, if the supplier is not located in the Member State where the substance or mixture is placed on the market and he has nominated a responsible person for that Member State, a full address and telephone number for that responsible person shall be given.

Where an only representative has been appointed, details of the non-Union manufacturer or formulator may also be provided.

For registrants, the information on the supplier of the safety data sheet and, if provided, on the supplier of the substance or mixture, shall be consistent with the information on the identity of the manufacturer, importer or only representative provided in the registration.

Emergency telephone number

References to emergency information services shall be provided. If an official advisory body exists in the Member State where the substance or mixture is placed on the market (this may be the body responsible for receiving information relating to health referred to in Article 45 of Regulation (EC) No 1272/2008), its telephone number shall be given and can suffice. If availability of such services is limited for any reasons, such as hours of operation, or if there are limits on specific types of information provided, this shall be clearly stated.

VI. Health Canada guidance for completing SDS Section 1

From: "Technical Guidance on the Requirements of the Hazardous Products Act and the Hazardous Products Regulations, WHMIS 2015 Supplier Requirements", Cat.: H129-64/1-2016E-PDF. December 2016. ©2016, Her Majesty the Queen in Right of Canada, as represented by the Minister of Health. The acronym "HPA" refers to the Canadian Hazardous Products Act. The acronym "HPR" refers to the Canadian Hazardous Products Regulations.

Item 1: Identification:

The required information in this section consists of:

· The product identifier used on the label (the brand name, chemical name, common name, generic name or trade name of the product)

· Other means of identification of the product (any other common names or synonyms by which the product is known)

· The recommended use of the product (a brief description of what the product actually does, such as “flame retardant”) and any restrictions on its use

· The initial supplier identifier (the full name, address and telephone number of the Canadian manufacturer or the Canadian importer of the hazardous product). “Manufacturer” is defined in subsection 1(1) of the HPR. Canadian importer means the person who, in the course of business in Canada, is responsible for importing the hazardous product into Canada

· An emergency telephone number and any restrictions on the use of that number (e.g., days and hours of operation), if applicable. The emergency telephone number is a telephone number that will enable a caller to obtain information regarding the hazardous product. It does not have to be a Canadian telephone number. If the language spoken at the emergency telephone number is neither English nor French, this should be indicated on the SDS as part of the restrictions on the use of the number.

Other means of identification of the product: The SDS must also disclose other names and synonyms that are commonly known in the work place. It is not expected that a long list of common names and synonyms would be provided.

With regard to the address that must be provided as part of the initial supplier identifier, this may be any valid Canadian postal address such as a full street address of the premises of the supplier or a post office box number with the address of the post office. A Canadian distributor who is not a Canadian importer may provide their contact information in lieu of the initial supplier identifier. For further information about this exception, see the Technical Guidance for section 5.8 of the HPR.

Under the HPR, a distributor who buys a hazardous product, re-labels the product and then sells it, is considered to be the initial supplier of the hazardous product. In this situation, the Canadian distributor must provide his name, address and telephone number on the label and SDS.

If a hazardous product is being imported only for use in the importer’s own workplace, the Canadian importer may retain the name, address and telephone number of the foreign supplier on the SDS instead of replacing it with his own contact information. This is the only situation in which a hazardous product, which is intended for use, handling or storage in a Canadian work place, may be imported into Canada with only the name, address and telephone number of a foreign supplier on the SDS. For further information, see the discussion in section 5.9 of the HPR.

In the case of a hazardous product that is being imported into Canada from a foreign supplier, but that is not intended only for use in the importer’s own work place (i.e., the importer does not qualify for the exception specified in section 5.9 of the HPR), it is the Canadian importer (i.e., the Canadian party who is responsible for bringing the hazardous product into Canada) whose name, address and telephone number must be provided on the SDS. The Canadian importer is responsible for ensuring that the importation of the hazardous product is in compliance with the requirements of the HPA and the HPR (e.g., labels and SDSs).

It would be acceptable for the SDS to include the contact information of both the Canadian importer and the foreign-based supplier. Additional information may be included on the SDS, as long as the information is not false or misleading (section 14.2 of the HPA prohibits information that is false, misleading or likely to create an erroneous impression with respect to the information that is required to be included in a label or SDS for a hazardous product).

[Rev. 8.9.2024]

[1] Minimum SDS requirements vary with jurisdiction. In some cases, instead of a burgundy label, a field may include a note identifying particular jurisdiction(s) requiring it.

[2] Applies to GHS-classified mixtures, on labels for packaged products and on the SDS for bulk-delivery products. The EU/EEA requirement goes into effect 1 January 2024 for industrial-use products. Not presently relevant to other jurisdictions.

[3] This shortcut is equivalent to clicking on the Help button on the entry form, and selecting “Background for this section”.

[4] GHS hazard (H-) statements and precautionary (P-) statements may also be available, in the Phrase Translations section of the program. Refer to the background help for the "2 Hazards" tab.

[5] A supported non-English language is one for which the program contains internal resources. These languages have a trailing asterisk (*) in the alternate language drop-down menu. Refer to “Alternate language selection” in the text.

[6] Generally an SDS should not have blank areas. You can instead indicate that the information is not available (and possibly offer an explanation for its unavailability), or that the topic is inapplicable. The program will in some cases skip a topic on the generated SDS when a field has no entry. This approach won’t be adequate if the jurisdiction requires an entry for the topic, however.

[7] You can also open the stock phrases dialog from the File menu (File -> Stock phrases). In this case, there is no current location of the cursor, and thus the Add example where used and Pas[t]e selected phrases buttons are disabled.

[8] Minimum SDS requirements vary with jurisdiction.

[9] However, the NPIS will log the UFI when you submit an SDS to them, provided that the UFI is clearly printed on the first page of the SDS.

[10] Individual explanations for these identifiers appear below. You can find these fields by clicking on the Show more button.

[11] If at this point you decide that you don’t want to keep the link, click on the Skip button. Then click again on the Link(ed) button, and select “Clear Substance link to this SDS”.

[12] Also refer to the discussion under the Substance name field, “Copying over/removing supplemental information”.

[13] “REACH” refers to the EU regulation for Registration, Evaluation, Authorisation and Restriction of Chemicals.