Manage and distribute to each customer a compliant Safety Data Sheet for all chemical product is a legal requirement. Solvay fulfills this requirement using SAP EHS Tool and Automatic SDS distribution based on the SAP EHS system

There are a lot of training material available on this topic - check it out!

Contents

Regulatory context

EU regulation (applied in all other zones)

- Mandatory update according to the progress of the product knowledge and of the evolution of the regulation.
- Set in compliance with the local regulation if necessary (ex : Germany or UK).
- Distribution at least at the time of the first shipping of a chemical product.
- Re-distribution in case of a ‘significant’ modification in terms of safety for all the previous recipients within the last 12 months.

US regulation

Official text : OSHA Hazard Communication + SARA 313 “Supplier Notification”
- One SDS per dangerous good, translated in the official language(s) of the destination country. 
- Mandatory update according to the progress of the knowledge (about the product) and of the evolution of the regulation. 
- Set in compliance with the local regulation if necessary (Canada and Mexico). 
- Distribution at least at the time of the first shipping of a chemical product 
- For products that contain SARA 313 “Toxic Chemicals” (cf chapter 15 of the SDS), an SDS must be sent with the first shipment of the year. 
- Distribution in case of a ‘significant’ modification in terms of safety at least at the time of the next shipping. 

Chinese regulation

Korean regulation

1) what are the laws regulating the sending of the SDS?
>> "K-REACH (MoE)" and "MoEL Public Notice No. 2013-37"

2) Is it mandatory to provide the SDS at the order? 
>> Yes, it's mandatory to provide SDS to the customer (i.e. Ship-to) at the 1st order or at R&D sample delivery. 

3) Is it mandatory to resend SDS that have underwent a major revision to the past customers, like in Europe?
>> Yes, we have to resend SDS after a major revision of following contents or K-REACH registration (as downstream user communication). But there's no specific period to regularly resend.

1. Product & Company Identification
2. Hazards identification
3. Composition Information on Ingredients
4. First aid measures
5. Explosion, Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls and Personal protection
9. Regulatory information

Japanese regulation

In Japan, the Law concerning Pollutant Release and Transfer Register (“PRTR Law”, Law No. 86 of 1999, as amended) regulates rules regarding SDS.

Under the PRTR Law, when a supplier intends to transfer chemical substances or products which contain 562 designated substances, the supplier have to provide the SDS to its customer.
In principal, the supplier have to provide the SDS on a transaction basis. In case the supplier and the customer trade the same products continuously or regularly, supplier may omit the provision of the SDS. However, in such cases, the supplier must provide the SDS whenever the customer requests.
When the supplier modifies the SDS, the supplier is obliged to make efforts to provide the modified SDS to the past customer.

Indian regulation

In India, normally the following two rules govern the manufacture, storage transportation of Chemicals:
1) Manufacture, Storage and Transportation of Chemicals Rules, 1989 (MSTC Rules)
2) Motor Vehicle Rules, 1989

As per provisions of the Motor Vehicle Rules, transporter is required to be provided with necessary information of chemicals which it is going to transport, according to the same SDS is required to be given to transporter. Further, as per MSTC Rules, every occupier is required to maintain data in respect of chemicals handled by him and keep the same updated.

In view of the above, it is obligatory to provide SDS with consignment.

Thai regulation

Thailand does not promulgate the REACH like requirements in the country right now.
There is only one regulation from the Ministry Of Industry (MOI) called "GHS compliance for Hazardous substance 2012 (B.E.2555)" which requires an importer to prepare the SDS according to GHS template and provide it to the customer, except in case that the customer has its own specific template requirement.
There are several other laws related to safety matters in Thailand for example :
** Labor law, employer has to provide the chemical safety information to the employee
** Transportation, the law requires a pack of document during transportation in case of accident so that a driver or the fire team can look at that (SDS is included)

It is not mandatory to provide the SDS at the order but in practice we do provide it to the customer in order to minimize any risk/liability of our own.

It is not mandatory to resend SDS that have underwent a major revision to the past customers but it can be provided upon the customer's request.

- One SDS or SIS per Commercial Product (regulated or not)
- The Business Unit which manufactures the product is responsible for the SDS creation and update. 
- The regional Customer Service which put the product on the market is responsible for the SDS distribution.

SDS Distribution Pre requisite

Product

- Material

Flag "Environnmentally relevant" flag must be activated in the BasicData2 View of the material master ==> if not: No automatic distribution

In PF1 : Quality code <> "X" must be defined in the Sale Organisation View ==> if not: No automatic distribution

- Commercial Product

Material assignment need to be done between Material code and PROD_COM specification  ==> if not: Error

SDS variant for the country and in the corresponding translation must be available ==> if not: Error

Sales

- Sales Organisation

Specific customizing for "SDB" correspondence need to be defined sales organizations in scope

- Sale order

Order type :  The following order type are active for SDS generation sales orders in scope

- Customer

Ship-to-Party or Sold-to-party can be set up by default by sales organization. However, in case they are in different countries, the customer service must ensure that distribution will be done to the Ship-to-Party, unless the Sold-to-Party is a distributor, and our final customer.

Variant and Language by Country

Link Generation variants per country

Trigger for Distribution

Customer order input (SD_CALL)

If the ‘ship to’ customer has not already received the same SDS/version within the last 12 months (all zone except NA or within the calendar year for US & CA (which is above the SARA 313 requirements).

Uploading of a new major version of the SDS (SUB_CALL)

The new SDS is sent to all the recipients for whom the previous version was distributed within the last 12 months. (all zone except NA).
Not required for US.

Manual printing (PRINT_CALL or MAN_CALL)

In case of customer request or for all the samples dispatched.

SDS Distribution Process

Sender

• In WP1  : A unique generic sender email address
• In PF1  : Email address by Sale Organisation. If not available the "Customer Care Service Representative" email 

Recipient

• A dedicated partner function if defined for the sales area ("Z6") or, as priority 2, the contact persons ‘ZS’ (WP1) and 'ZM' (in PF1) if defined in the general view
  
• QuickFDS email address in copy for SDS distribution traceability (only used by SBS EMEA today)

Language 

• Official language(s) of the ship to country
• In addition, the recipient’s communication language if different from the previous one(s) and if the SDS is available in such language

Cover Letter

• A standard text translate in several languages (communication language of the customer if available)
• One for the first distribution
• Another one in case of subsequent distribution 

Communication Mode

• INT for email
• LET for print
• FAX for fax (only available in WP1)

Shipping orders follow-up

SDS Distribution followup

• CVD1 transaction is the way to analyse all distribution process generate in SAP EHS system

Distribution recycling process

• In CVD1 transaction a manual process is available for SDS distribution error recycling.

BW reporting - KPI and Error analysis

• BW report exist for SDS Distribution KPI
• % of SDS Shipping error by zone and country
• % of SDS distribution by Email / Letter