Safety data sheet change management

Turn new classifications, exposure limits and Candidate List entries into updates to your safety data sheets.

ProjectsSafety data sheet change management

  • Dara Whitcombe
  • Leila Moradi
  • Rory Gallagher
Ormsby’s 6 safety data sheets that a recent rule change touches, with each change and its status.
Safety data sheetProposed changeStatus
LR 200 laminating resinAdd H341 and the GHS08 pictogramExpert review
AD 75 structural adhesiveShow the diluent’s new entryDrafting
FR 900 brominated resinAdd TBBPA’s Candidate List entryPublished
AH 52 anhydride hardenerNew TMA limit, 0.0005 mg/m³Published
EL 420 casting resinAdd H341 and H373 (nasal cavity)Published
CR 310 coating resinAdd H341 and the GHS08 pictogramPublished

LR 200 laminating resin EU

Status: Expert review

Needs H341 from 1 February 2027

Entry
o-Cresyl glycidyl ether: Muta. 2, H341
In LR 200
12% o-cresyl glycidyl ether
Early
Suppliers may apply it sooner

Your expert signs off every change

You get a proposal for each sheet a rule change touches, with the evidence behind it, and monitoring for the next change.

Approval

Illustrative project

Dara Whitcombe

Status: Approved

Head of Product Stewardship, after checking the changes to all 3 sections against their sources

  • 2.2 Label elements

  • 8.1 Control parameters

  • 15.1 Regulations

Foresight does the research

Your team brings what only it knows, and your expert makes the call at each checkpoint.

Tasks

Illustrative project

3 of 5 tasks done.

  1. Share your safety data sheets

    Your team

    Status: Done
  2. Draft the scope

    Foresight

    Status: Done
  3. Agree the scope

    Checkpoint

    Dara Whitcombe

    Status: Approved
  4. Draft the change proposals

    Foresight

    Status: In progress
  5. Approve each change

    Checkpoint

    Dara Whitcombe

    Status: Not started

Kept current once it’s approved

Monitoring watches the rules behind your safety data sheets. When one moves, Foresight traces it to the sheets it affects and proposes the change for your expert to review.

Monitoring

Illustrative project

Watching 4 measures behind the proposals

  • CLP Annex VI harmonised classifications

  • Germany’s workplace limits, TRGS 900

    The June 2026 amendment added limits for cobalt, pyridine and EDAO, and replaced the limit for trimellitic anhydride. Rechecked, only AH 52 contains one of them, and its German sheet now carries the new limit.

    Status: To review
  • UK REACH Candidate List

  • CLP Article 30, deadlines for updating labels

What we need from you

Four things, shared at setup before the project starts.

  1. Your safety data sheets

    The current version of each sheet, for every market you supply.

  2. Your formulations

    What each product contains and at what concentration, so a new classification can be traced to every sheet it affects.

  3. Your markets

    Where each sheet is supplied, because exposure limits and listings differ by country.

  4. Your approver

    The person who agrees the scope and approves each change before it’s published.

What teams ask about this project

How do you work out what changes on each sheet?

Monitoring finds the rule change, such as a new harmonised classification, a national exposure limit or a Candidate List entry. Foresight traces the substance through your formulations to every sheet that contains it, and applies CLP’s concentration limits to see what follows. The same entry can add H341 to one sheet and not another, depending on how much of the substance each product contains.

Where does the evidence come from?

From the official texts: the delegated regulations that amend CLP Annex VI, national limit lists such as Germany’s TRGS 900, and the Candidate Lists that ECHA and HSE keep. Each proposal links to the source it relies on.

When must a revised sheet go out, and to whom?

REACH Article 31(9) says without delay: as soon as new hazard information, or information that affects risk management measures, becomes available, and when an authorisation is granted or refused or a restriction imposed. The revised sheet is dated ‘Revision: (date)’ and goes free of charge to everyone you supplied in the previous 12 months. UK REACH sets the same rule in Great Britain. A new harmonised classification applies from the date its delegated regulation sets, 1 February 2027 for the 23rd adaptation.

Who checks a change before it’s published?

The person you name. They agree the sheets, markets and formulations before any drafting starts, and check every proposal against its source. Nothing is published until they approve it. These checks reduce the risk of error without removing it.

What happens when a rule changes?

Foresight traces it to the sheets it affects and proposes the change, whether it’s a harmonised classification or an exposure limit. Published sheets stay as they are until your expert approves the change.

What does it cost?

The price follows how many sheets, products and markets it covers. You see it with the scope, before any drafting starts.

Bring your current sheets to a demo

Tell us your products and the markets you supply. You’ll see the scope and the price before any drafting starts.