I don’t know about you, but we occasionally receive Safety Data Sheets which contain the same substance included twice. These are often for fragrances, which contain multiple component substances.
It’s easy to see how this can happen, because the supplier has mixed two separate fragrances together to make a new fragrance, and simply placed the list of components from each fragrance into Section 3.2 without checking for duplicates.
This may seem like an administrative error, but it has serious consequences for some types of hazard, especially sensitisers. This is because sensitisers are classified individually, you don’t add them all together.
It means that if you have a Category 1 or Category 1B sensitiser present twice at 0.6 % each time, it is actually present at 1.2% total, which would mean that the product should be classified as a Category 1 or Category 1B sensitiser, and it would need a symbol, signal word, hazard statement and appropriate P statements.
If the person classifying the fragrance doesn’t spot that there has been a duplication, the fragrance would only be classified as EUH208, Contains xxxx, may produce an allergic reaction. Then if you, in good faith, use the fragrance as a mixture in your mixture, the lower, incorrect concentration might lead you to under-classify the product, and also to not identify the sensitiser on your label, which could put people who are already sensitised at risk.
Of course, some other hazards, such as carcinogenicity, are also classified in this way, but they are unlikely to appear in fragrances, and sensitisers are the most likely hazards where this applies to.
So what can you, the person classifying a scented product containing this fragrance, do about it?
The first thing we do for this type of classification, where we have the Safety Data Sheet, is to go back to the component data in Section 3.2 of the SDS, and use that, rather than treating the fragrance as if it were a component substance (the “mixtures in mixtures” approach).
Secondly, we put all of the relevant information into an Excel sheet, which is quick and easy to do if the SDS has not been secured. It’s simply a copy and paste job, although sometimes the information is present in a single cell, when you may need to use the “text to columns” feature in excel to make the information fit into the columns you want.
The minimum number of columns we use are:
- ID number(s)
- CLP classification
- % w/w (use the maximum figure if this is a range, e.g. 5 – 15% becomes 15%).
Then, on the EC number or CAS number column, we use the conditional formatting function in Excel to highlight duplicate values, and I find the red text on red background option to be easiest to spot.
If there are any duplicates, you may want to sort the data by number order on the EC number or CAS number column, (remembering to include all of the other information in your sort!), so that the duplicates are next to each other.
Then it’s an easy job to add the duplicate weights together, type this information into the first entry, and then delete the second entry. You can use the sum function to do this for you, but if you copy the results back into the first entry, make sure you use the “paste values” function, otherwise things get very complicated (voice of experience).
Once you’ve added all the duplicate masses together and made sure you only have a single entry for each component substance, with the total mass, then you can go ahead and use the fragrance information in your product classification.
Of course, if you’re using two fragrances in your scented product, you will then need to check your formulation to make sure that you haven’t got duplicates there as well.
The problem of duplicates in mixtures is not limited to fragrances, and can occur whenever similar mixtures are used together in a new mixture.
If you find a Safety Data Sheet containing duplicates, you may want to flag this up to your supplier, who is presumably unaware of their presence. This is particularly important if their product has been classified lower than it should have been because of duplicate components. Hopefully this will help both your supplier, and you in the future, as it may prompt them to check all of their SDSs to ensure this type of error is dealt with.
GHS Classification Courses from TT Environmental Ltd
15th July 2019
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