At a time when English has become the core language of business virtually all over the world, we prepare more and more commercial and technical documents in it. In many cases, such documentation is sufficient to run the business and meet customer expectations. Can we apply the same principle to Safety Data Sheets? The answer is: it's complicated. Of course, first of all, we should look at the regulations that say that Safety Data Sheets should be prepared in the official languages ​​of the Member States on the territory of which the substance or mixture is placed on the market, unless the Member States concerned decide otherwise. However, no country in the European Union has decided otherwise. This means that in order to remain fully compliant with the regulations, an appropriate language version of the Safety Data Sheet should be prepared for each member state. In fact, we could end our considerations there, if it were not for the fact that business is always much more creative than the legislators.

Can English be a universal solution?

As stated in the first paragraph of this article, a widely used approach is to provide Safety Data Sheets only in English, regardless of the market into which the substance or mixture is introduced. Of course, as we indicated in the previous paragraph, this solution is not 100% compliant. However, it is also worth paying attention to another aspect of this solution. The primary purpose of the Safety Data Sheet is to inform the user about the risks that may be associated with the use of the product, as well as the countermeasures that should be used to minimize this risk. We must remember that the user of the substance or mixture, and therefore also the Safety Data Sheet, is not only our client's purchasing department. The Safety Data Sheet is primarily intended to ensure the safety of employees who have direct contact with the product, whether at the manufacturing site or in the warehouse. There is a high probability that the Safety Data Sheet provided in a language other than the official one will remain incomprehensible to these employees and therefore will not serve its purpose.

Translating the Safety Data Sheet is not just a matter of language

Assuming, however, that as a result of the application of internal procedures, our client will extract the most important information from the Safety Data Sheet and, based on it, create appropriate operating procedures, the problem from the previous paragraph is solved (although not completely, as indicated by Article 35 of the REACH regulation - this is nevertheless topic for a separate discussion).

The Safety Data Sheet is, however, a specific document, referring to international, but also national regulations. The essence of the complexity of translating the Safety Data Sheets is not only the language issue, but also its appropriate adaptation so that it refers to the relevant legal acts. The two most important parts of the Safety Data Sheet that will require such adaptation are sections 8 and 15. In section 8 of the Safety Data Sheet you will find information on the occupational exposure limits for substances in the working environment (OEL), these are, in turn, determined at the national level and as such may vary between the countries. It is also possible that a given substance will not have an OEL value assigned in Ireland for example, but it will in the target country. A direct translation of the Safety Data Sheet in such case, without adapting it, will result in the lack of an entry on the OEL value for this substance in Section 8 of the translated document. Such Safety Data Sheet will, therefore, not be 100% correct.

Section 15 is a list of legal acts relating to the product and those relevant from the point of view of the Safety Data Sheet. In the case of this section we should not consider this to be a translation at all since, of course, national legal acts differ between Member States. Section 15 also contains references to legal acts applicable only in a given member state, such as WGK - German regulations regarding water hazard classes.  

As you can see, if we prepare the Safety Data Sheet only in English, without adapting it to the regulations of a given country, we risk that the prepared document will not be fully compliant with local regulations.

To translate or not to translate?

A fully correct approach to the regulations would require preparing a Safety Data Sheet in all languages ​​of the countries in which we want to market our product. A properly prepared Safety Data Sheet for a given market will be a definite advantage even during sales negotiations. The development of a Safety Data Sheet should be viewed as one of the elements of product development, just like preparing its label. To ensure uninterrupted and secured access to the sale of our products, it is worth ensuring that the preparation of our Safety Data Sheets for substances and mixtures is done by experienced experts who understand the requirements of the markets we are interested in.