SDS Authoring – South Africa

Regulations Involved

The primary regulation that oversees GHS in South Africa is the Regulations for Hazardous Chemical Agents, 2021 (RHCA). This regulation aligns with the UN Globally Harmonized System (GHS) Revision 8, 2019.

The South African National Standard (SANS) 10234 is aligned with GHS and may be used as an alternate guide. If any differences are presented between the RHCA and SANS 10234, the RHCA will take precedence.

There are also some supplemental regulations:

SANS 11014:2010 Safety data sheet for chemical products — Content and order of sections
SANS 10228 The identification and classification of dangerous goods for transport by road and rail modes
SANS 10232-4 Transport of dangerous goods – Emergency information systems Part 4: Transport Emergency Card (TREC)

These regulations were created to protect human health and the environment against the adverse effects of hazardous chemicals in South Africa. The RHCA will be enforced starting September 2022 and will have an 18 month transition period.

Who Does This Apply To?

Hazardous chemical substances and mixtures that are intended to be used at a workplace must comply with the requirements on classification, labelling, packaging, and safety data sheets according to the regulations.

The GHS requirements for classification, labelling and SDSs are not applicable to foodstuffs, cosmetics or pharmaceuticals in their final form

Is This Regulation Mandatory?

GHS requirements were voluntarily for companies since 2012 through SANS 10234. However, the new adopted RHCA now makes GHS requirements mandatory.

From September 2022, manufacturers, importers, suppliers and retailers of hazardous chemical substances and mixtures for the workplace must comply with the requirements outlined in the RHCA.

It is also important to note that transport is highly regulated in South Africa. If your product is regulated for transport, it is mandatory to carry a TREC. This card provides documentation outlining the hazards and precautions for the goods the driver is transporting.

What are the risks if a company chooses not to comply?

According to the RHCA, any person who fails to comply with the provisions of this regulation is subject to a fine or imprisonment of up to six months. In the case of continuous violation, an additional fee of R500 per day or an additional imprisonment day for each day the offence continues.

Our Procedure

Required Product Information
Nexreg’s consultants first acquire information about the product including the full formula (laboratory analysis) or the current/prior SDS (if available), and raw material SDS’s for components of mixtures. We typically ask that a “required product information sheet” be filled out with the information needed to generate the SDS. If your product information is confidential, our team will provide a non-disclosure agreement.
SDS Generation Process
Nexreg creates a formula breakdown (if required) and inputs the information digitally for formula analysis. The product formula is checked against databases for chemical hazard, government regulatory, and physical properties requirements.
Product Classification
The product classification is determined based on the hazards of the chemicals in the product, the specific requirements of the country, and other available information such as test data. The chemicals required to be disclosed on the SDS are determined based on their individual hazards and statements are selected to be included in the SDS based on the product characteristics and GHS classification.
Final Adjustments & SDS Review
A senior consultant will review the determined hazard classification for correctness before the consultant authors the final SDS. The final SDS is then put through an additional in-depth review process to ensure a high quality, compliant document is issued.

We’re Regulatory Experts

For quality compliance resources for companies of all sizes across the world.

I am very satisfied with the work provided by Nexreg. The work has been through, timely and reasonable. Additionally, both Mike Harvey and Nazifa Beganovic are very knowledgeable. Mike and Nazifa’s efforts have been an essential part of getting our MSDS program on track and positioned for the Global Harmonized System.

Jack CoverBonsal American, Inc.

We’re often asked by our clients to meet next-to-impossible deadlines, which means that we’re often forced to ask our vendors for the impossible. Working with Nexreg makes my job easier. They are experts at what they do, they pay attention to detail, and they make suggestions and offer advice – which makes us look like the experts. For regulatory compliance and translations, Nexreg ranks as one of the strategic partners we can always count on.

John S. WolowiecZoltun Design