In Japan & Australia, SDS is required to sent to Sold To Party, instead of Ship To Party?

[Former Member]

Hi SDN expert.

I have recently received a requirement from Japan and Australia that our EHS SDS automatic shipping process should modified to ship SDS to Sold To Party, instead of Ship To Party (standard delivered by SAP).

This post is not about discussing the technical feasibility.  I like to get feedback from EHS and regulatory subject matters in these countries. Are your organization actually doing the same thing, only sending SDS (Safety Data Sheet) to the Sold To Party. and the Sold To Party will responsible to forward or provide their own SDS to the product recipients?

In our case, Sold To Party sometimes are our distributors or not the direct consumer of our products. Our Japan product stewards discouraged to send SDS with our company logo to the consumer (Japan domestic sales), thinking this may be a risk for liability.

Thanks for your valuable inputs.

KC

[christoph_bergemann · Accepted solution]

Dear K.C.

interpretation of legal requirements are normally not part of the job of a IT consultant.The demand what is "correct" must be defined by the corrersponding organization unit within a company (e.g. legal department). And even if you consider this department many companies have "on the top rules" to make sure that they can deliver the material and the customer is satisfied.

regarding Australia: may be check:

http://www.safeworkaustralia.gov.au/sites/swa/whs-information/hazardous-chemicals/sds/pages/sds

http://www.chemlink.com.au/msds.htm

http://www.deir.qld.gov.au/workplace/hazards/hazchem/managing-risks/labelling-and-safety-data-sheets...

Regarding Japan: you will find easily in most cases similar links

C.B.

[Former Member · Accepted solution]

Chris,

Thanks a lot. The links are very useful.

KC

[christoph_bergemann · Accepted solution]

Dear K.C.

may be check as well:_

http://www.jcr-link.com/INFO/EN/JA/Regulations/MSDS.html

You will find links like this:

http://www.cirs-reach.com/GHS_in_China_Korea_and_Japan.html

or

http://www.ncbi.nlm.nih.gov/pubmed/20134103

using general search terms

If you are statisfied with answer please close thread.

As mentioned: the legal demand and how to interpret  is not (in most cases) job of IT consultant. Regarding your discussion in:

http://scn.sap.com/thread/3422262

Keep in mind that any legislation is different and many companies do have "on the top rules" regarding SDS distribution; it is not easy to take care these rules (legislation and on the top rules). At the end you can end up in complex process (and complex coding). Therefore if possible in the are of SDS/MSDS distrbution: try it to keep it simple ! (and prepare a good ! documentation !)

C.B.

[Former Member]

Hello K.C.

With regard to your questions, I'd like to recommend the following ebook for your reference:

• Overview of GHS Development in Asia-Pacific in 2013

https://chemlinked.com/en/expert-article/ebook/ebook-33overview-ghs-development-asia-pacific-2013

A progress report and in-depth analysis of the major GHS implementation events observed in 9 countries/areas across the Asia Pacific region throughout 2013, including Japan and Australia.

For chemical regulatory issues you may encounter in the future, please feel free to contact us and see if we can help to solve them.   https://chemlinked.com

We have strong technical support from experienced experts of REACH24H Consulting Group.