Relying on third-party Safety Data Sheets (SDSs) can expose a business to serious compliance, safety, and legal risks — especially under Australian WHS and GHS regulations. Here’s a detailed breakdown of the key dangers:
- Outdated or Non-Compliant SDSs
- Regulations change frequently (e.g., GHS 7 → GHS 8, upcoming GHS 9 in 2025). Third-party SDS providers may not update documents promptly.
- Using an outdated SDS means you could be classifying, labelling, or managing chemicals incorrectly — breaching WHS Regulations 2022 (WA) or equivalent state legislation.
- Regulators (e.g., WorkSafe, EPA) can issue notices or penalties for using non-compliant SDSs.
- Inaccurate Hazard Classification
- Many third-party SDSs use generic or global hazard data that doesn’t reflect Australian-specific classifications under the AICIS or Dangerous Goods Safety Regulations 2007 (WA).
- This can result in:
- Missing or incorrect DG classes, packing groups, or UN numbers.
- Wrong or missing Pictograms, Signal Words, or H/P statements.
- Misleading risk assessments or incorrect PPE recommendations.
- Incorrect Local Regulatory References
- SDSs sourced overseas often cite EU REACH, US OSHA, or Canadian WHMIS legislation — not Australian WHS or AICIS frameworks.
- This creates confusion for workers and auditors, and fails to meet the requirement that SDSs must be prepared in accordance with Safe Work Australia’s Code of Practice.
- Liability and Legal Exposure
- If an incident occurs and the SDS information was wrong or incomplete, the importer, manufacturer, or supplier (not the third party) is legally responsible.
- You can’t transfer this duty of care — regulators expect you to verify the SDS accuracy for each chemical used or supplied.
- Missing Toxicological or Ecological Data
- Many generic SDSs omit or summarise toxicological and ecological information to save cost.
- This makes it impossible to perform accurate risk assessments, NPI reporting, or waste management planning.
- Inconsistent Format or Missing Sections
- Poorly formatted or incomplete SDSs can make it hard for workers to find critical data quickly (e.g., first aid, spill response).
- The SDS must have all 16 sections clearly completed and compliant with Schedule 7 of the WHS Regulations.
- Loss of Control Over Revisions
- If you rely on a third-party database, you often don’t know when an SDS was last updated or when it will expire.
- Without an internal review system, your chemical register quickly becomes non-compliant and out of date.
Best Practice: Maintain Verified, Local SDSs
- Require all suppliers to provide current (≤5 years old) Australian-compliant SDSs.
- Use a chemical management system (like Lupin Chemical Management) that:
- Tracks SDS expiry dates and updates automatically.
- Verifies local regulatory compliance (AICIS, WHS, DG, GHS).
- Allows internal review and version control.
- Generates compliant labels and risk assessments directly from validated SDS data.