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In This Section

1. When we import a chemical, do we need to make a new MSDS?
2. Where can I get MSDS's in other languages such as Spanish?
3. What language does an MSDS need to be in?
4. Where can I get information about European requirements for MSDS format?
5. How do Canadian MSDS's differ from the U.S.?
6. What about other countries?

1. When we import a chemical, do we need to make a new MSDS?
For the most part, yes. According to an OSHA Interpretation Letter from January, 2000:
When chemicals are imported into the United States, the person (meaning one or more individuals, partnerships, associations, corporations, business trusts, legal representatives, or any organized group of persons) who imported the product automatically becomes the responsible party. OSHA only has jurisdiction over transactions which affect commerce within the United States. As the importer is the first point of contact within this country, the importer is therefore responsible for complying with the HCS; the HCS requires that the importer include their name on the MSDS and label.

We are unaware of any exemption from these responsibilities under the North American Free Trade Agreement (NAFTA). Being the "responsible party" entails important obligations. See our MSDS FAQ question "As a distributor, can we change the name and address on an MSDS" for more on the obligations of the "responsible party".

As the "responsible party", can an importer simply substitute their name and address on a foreign-issued sheet? Yes, provided that the sheet has all of the information required by the Hazard Communication Standard. But do not simply assume that any MSDS you receive has all the required information or that the information is correct! You should independently verify that the hazard information/precautions conveyed are accurate, documenting those efforts if appropriate. You may find our MSDS FAQ question "Who can write an MSDS" of some use.

If an importer does not wish to deal with checking/verifying the sheet information, there are firms that will, for a fee, take the MSDS's you have and create new ones for you. See our MSDS Suppliers/Translators page for some examples (if you contact any of those firms, please let them know you were referred from their ad on our web site).

Canada's WHMIS regulations appear to have work the same way as OSHA's in requiring the importer to produce a compliant MSDS if one is not available.

We have no information regarding the import or export of MSDS's to/from other countries, but it appears that most countries have regulations similar to the U.S. regulations.



2. Where can I get MSDS's in other languages such as Spanish?
There are several sites listed on our MSDS site list that offer multilingual and/or regional MSDS's. Some of the most valuable ones are:

Site	# MSDS	Languages
MSDS Solutions	115,911	English, German, Chinese, Dutch, Spanish and French. This site houses over 3,500,000 MSDS's!
Merck KGaA	12,000+	English, French, German, Spanish, possibly more. Requires free registration.
Eastman Kodak	1,500	English, Danish, Dutch, Finnish, French, German, Italian, Norwegian, Portuguese, Turkish. Note: Some versions require following a link to a regional web site.
E. I. du Pont de Nemours and Company	1,400+	MSDS on their products. Select from approximately four dozen different languages/countries in pulldown menu and then search by product name/synonym or DuPont MSDS #. ANSI-compliant sheets in PDF format.
Rhodia Silicones	1,000+	Use their JavaScipt-based Product Finder to locate the product you desire, then click the MSDS link. ANSI-compliant sheets in HTML format. Site requires (free, but detailed) registration and login. Different languages available depending on your location/region.
Dojindo Molecular Technologies	396	English, Japanese

If you only need to translate a few words, MexicanLaws.com offers a 10,000 phrase English-Spanish chemical dictionary. Automatic translation sites such as Google Language Tools and Yahoo's Babel Fish provide translation in a number of language pairs, but use these with caution as word-by-word translations are generally not reliable. If anyone knows of other foreign language sites or technical dictionaries, please let us know and we'll add them to our list! If these sites do not meet your needs, you still have options. First, try calling the manufacturer and see if they can provide the MSDS in the appropriate language. With the advent of the Canada-U.S.-Mexico NAFTA treaty, there is a good probability that they might have the MSDS in Spanish or French. Second, if you do not have a large number of MSDS you can translate them yourself (or have someone translate them). Some companies that provide these services for MSDS's and other technical documents include: eQuality Translation Services Global Language Translations and Consulting Global Translations ISI Translation Services Nexreg Compliance, Inc Solvent Engineering Translink bvba WordDoc Translations

We have numerous English/Spanish products such as binders, NFPA and HMIS labels, signs, training posters and more at www.SafetyEmporium.com!



3. What language does an MSDS need to be in?
Almost every country has regulations that require the MSDS to be in native language(s) of that country. So an MSDS in the U.S. or U.K. must be in English, one in Norway must be in Norwegian, an MSDS in Canada must be available in both English and French etc.. In general, it is the manufacturer or distributor (whichever places the product for sale in that particular market) that is responsible for creating the sheet. Some links which mention language requirements include:
• Classification and labelling of dangerous chemicals: Guide to chemical suppliers (Norway)
• The Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (UK)

4. Where can I get information about European requirements for MSDS format?
New European Union regulations on MSDS's, labelling and packaging are being phased in to comply with the Globally Harmonized System (GHS). Regulation (EC) 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP) implements the GHS. The CLP is a stepwise replacement of Directives 67/548/EEC (substances) and 1999/45/EC (preparations).

The European Chemicals Agency maintains an up-to-date list of the legally-required harmonized classifications and labellings for substances in the EU. SImply click on the "Search for Chemicals" box to search by name, EC or CAS number. The EU's REACH regulations are creating a central registration point for chemical information as well.

The now superceded directives 67/548/EEC and 99/45/EC required producers of dangerous chemicals in EC (European Community) member states to provide industrial and professional users with detailed health, safety and environmental information and advice about their products in the form of safety data sheets. Directive 91/155/EEC, as amended by Directives 93/112/EEC and 2001/58/EC, set out the requirements for the information which should be included in a safety data sheet. You may download 2001/58/EC in various languages from the European Union web site. This site also has Directive 98/24/EC which outlined employer responsibilities in detail. Environmental Software and Services has a nicely formatted section-by-section discussion of European sheets and mentions their differences with U.S. requirements.

The United Kingdom's law governing MSDS's (among many other items) is the Chemicals Hazard and Information and Packaging for Supply Regulations (CHIP), which is also being phased out as the GHS is phased in. An important difference between OSHA regulations and CHIP is that if an MSDS is changed, CHIP requires the supplier to notify anyone who received the chemical in the previous 12 months. Likewise, European regulations require that specific risk phrases and safety phrases appear on the labels and safety data sheets, whereas OSHA simply requires that all hazards and precautions be clearly communicated without specifying a code scheme. Additional information can be found in the COSHH regulations.

The German Employers Federation for the Industry (BDI) produced a handy guide for those formulating EC-compliant sheets. Their catalog of standard phrases translates key phrases into the official languages of the EU member states. This project is meant to help a supplier or producer of a chemical produce a correct MSDS. This document is available in German and English.

Two other resources that may help are Chemical Safety Cards produced by the International Occupational Safety and Health Information Centre and Status of GHS Implementation By Country at the UNECE.

Be sure to check out our MSDS Suppliers and Translators and Software pages; there are a few vendors on there that are based in Europe or offer services with EU compliance.



5. How do Canadian MSDS's differ from the U.S.?
In Canada, every material covered by WHMIS (Workplace Hazardous Materials Information System) must have an accompanying MSDS (see this SaskLabour site on how to determine what is covered). The regulations covering these tend to be a bit more specific and strict than the U.S. OHSA's. See the references in our WHMIS entry for more detailed information, information in other languages, and useful web links.

One of the major differences is when an MSDS must be updated. WHMIS MSDS must be updated every three years or when there is a formulation change. OSHA only requires an update when there is a change in formulation or health information (see the Compliance section of this FAQ).

Another major difference is in the Hazardous Ingredients/Identity Information. The WHMIS rules of exposure tend to be much more specific and strict then OHSA. For instance, WHMIS requires the % concentrations of hazardous ingredients be disclosed on the MSDS (unless exempted at the time of registration with the HMIRC). Also, there is a difference in the exposure limit and/or toxicological information. OSHA requires PEL and TLV to be listed while WHMIS requires the TLV as well as the LD₅₀ value.

The rest of the sections are more or less the same (there are a few tiny differences).

Finally, note that MSDS's are required to be supplied in both English and French. These can be two different sheets, or both languages can be on one sheet.

For more information about Canadian MSDS requirements, visit this Health Canada page.



6. What about other countries?
• Australia - The Australian Safety and Compensation Council has the National Code of Practice for the Preparation of Material Safety Data Sheets [NOHSC:2011(1994) and NOHSC:2011(2003)] available as PDF downloads.
• Mexico - The official regulation is Norma Oficial Mexicana NOM-018-STPS-2000, Sistema para la identificación y comunicación de peligros y riesgos por sustancias químicas peligrosas en los centros de trabajo. Or for you English-speaking folks, Official Mexican Standard NOM-018-STPS-2000, System for the identification and communication of hazards and risks for hazardous chemical substances in the work place. We are unaware of any sites that offer this entire document for free, but thanks to our friends at the Research and Special Programs Administration of the U.S. Department of Transportation, we now have English translations of Appendices C and D of NOM-018 available on our web site.

  To obtain the official Mexican standards in Spanish visit http://www.economia.gob.mx/. Human Resources and Social Development Canada has some information on Mexican Labour Law as does the US Department of Labor.

• Norway - The Norwegian Pollution Control Authority has a document titled Guidance for chemical suppliers which has links to the basic safety data sheet regulations in Norway.
• ??? - If anyone knows of sites that detail MSDS regulations in other countries please contact us. Thanks for your help!

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