Entering 2024 with Safety Data Sheets

As we approach the year 2024, questions have begun to arise regarding the new process awaiting safety data sheets. As of December 31, 2023, safety data sheets will only be prepared according to Annex 2 of the KKDIK (Turkey REACH) Regulation. This situation also closely concerns individuals holding the safety data sheet preparer certificate.

To better understand why such a change was made regarding safety data sheets, it is useful to briefly recall the processes of previous years. As known, with the enactment of the REACH Regulation in the European Union in 2007, Extended Safety Data Sheets (eSDS) began to be prepared according to this Regulation.

In Turkey, the KKDIK Regulation, which harmonizes with the REACH Regulation, was published in 2017 and entered into force in 2018. It was stated that safety data sheets could be prepared in accordance with the KKDIK Regulation or the provisions of the "Regulation on the Preparation of Hazardous Substances and Mixtures" until December 31, 2023. Information about the transition period awaiting safety data sheets in the future was provided in the transitional provisions within the KKDIK Regulation.

The provisions of Transitional Article 2 within the KKDIK Regulation are as follows:

(1) If the annual quantity of substances manufactured or imported on their own or in mixtures before 31/12/2023 is one ton or more, the provisions of Article 7 and/or 8 or 17 or 18 between 31/12/2020 and 31/12/2023 apply.

(2) Safety data sheets will be prepared according to the Regulation on Safety Data Sheets for Hazardous Substances and Mixtures until 31/12/2023.

(3) Safety data sheets may also be prepared in accordance with this Regulation until 31/12/2023, starting from the effective date of Article 27, without applying the provisions of the Regulation on Safety Data Sheets for Hazardous Substances and Mixtures.

(4) A chemical assessment specialist may also prepare a safety data sheet according to the Regulation on Safety Data Sheets for Hazardous Substances and Mixtures.

In line with these provisions, chemical assessment specialists have been able to prepare safety data sheets both according to the KKDIK Regulation and the Regulation on Safety Data Sheets for Hazardous Substances and Mixtures in recent years. Individuals with a safety data sheet preparer certificate have only had the authority to prepare safety data sheets according to the Regulation on Safety Data Sheets for Hazardous Substances and Mixtures, but this authority will cease to exist as of December 31, 2023.

As of December 31, 2023, safety data sheets will only be prepared by Chemical Assessment Specialists according to Annex 2 of the KKDIK Regulation. It is recommended that companies do not forget this detail when planning their future processes.