Situation of Turkish SDS Regulation by publishing of KKDIK (Turkish REACH) Regulation
KKDIK Regulation, also known as Turkish REACH, was published on 23 June 2017 and enforced on 23 December 2017 in Turkey for chemicals within the scope of Chemical Control Legislations. Some Regulations were repealed upon the entry into force of KKDIK. In addition, some of them will be repealed upon the entry into force of some provisions of KKDIK in the future. Turkish SDS Regulation will be repealed as of 31 December 2023. That means the relevant provision of KKDIK allow the SDSs prepared in compliance with Turkish SDS Regulation by 31 December 2023.
Before telling the situation of SDS Regulation by the enforcement of KKDIK, it is useful to mention the Chemical Assessment Expert concept which is a new concept came with KKDIK and also the differences between Chemical Assessment Experts and Certified SDS experts.
The registration dossiers are going to prepared by only the Chemical Assessment Experts. Although Chemical Assessment Experts can prepare the SDS in accordance with both KKDIK and SDS Regulations, Certified SDS Experts can prepare the SDS in accordance with only SDS Regulation. This is available by 31 December 2023. After this date, there will be no Certified SDS Experts concept because of SDS Regulation would have been repealed.
According to the above explanations Safety Data Sheets of the hazardous substance/ mixtures can be prepared in compliance with SDS Regulation No.29204 by 31 December 2023. Certified SDS Experts could author SDS according to Turkish SDS Regulation as Chemical Assessment Experts can author SDS according to both SDS Regulation requirements or KKDIK Annex-II requirements.
SDS Authoring
The Safety Data Sheet is a document that provides health and safety information about the product, substance or chemical which are classified as harmful. The content and scope of the SDS varies depending on the regulation and the language of the country concerned. There are 16 main headings and 48 subheadings in the MSDS structure generally adopted on the world. It is a requirement to prepare the SDS with the language of the country to which the product will be sent and in accordance with the county’s relevant regulation.
For example, if you are importing a product to one of the European Union countries, the SDS should be prepared in accordance with the European REACH Regulation Annex II (1907/2006) standards and the risk classification in accordance with CLP Regulation 1272/2008. In the European Union countries, that do not use English as their native language, it is more accurate to prepare an SDS in the language of the relevant country, although they can accept an SDS in English.
SDSs in Turkey, are authored in accordance with the provisions of the Turkish SDS Regulation No.29204 as the full name “Regulation on Safety Data Sheets for Hazardous Substances and Mixtures” published in 13 December 2014. The classification of hazardous given in Section 2 of the SDS and list of substances to be specified in Section 3 should be compiled taking into account the Turkish CLP Regulation No. 28848. These are the most important parts of the SDS and any mistakes will affect all parts of the SDS. For EU-compliant SDS, CLP Regulation 1272/2008 is also important for the relevant parts.
Another important part of the SDS is Section 14. In this section, international regulations must be known, and decisions of the relevant national / local competent authorities should be taken into account. This section provides technical information on how to transport the product. Regulations, ADR, ADN, RID, IMDG and IATA regulations, published by the United Nations, help to guide the criteria for the transportation of the product.
The authoring of the mentioned sections of the SDS requires having a broad knowledge in the technical sense. An improper compiled SDS could turn into a major problem during the chemical compliance period of the company.
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