WHICH FORM OF “REGULATORY TRANSLATION” APPLIES TO YOUR SAFETY DATA SHEET (SDS) DOCUMENTS?

When performing an SDS translation, one of the primary concerns is regulatory compliance. There are several types of regulatory compliance, and different translation agencies use the term “Regulatory Translation” with different meanings, including:

  • Format compliant
  • Content compliant
  • Phrase translation compliant

One form of regulatory compliance involves the formatting of the SDS itself. Different countries have different formatting requirements in spite of the Globally Harmonized System (GHS). The formatting of the SDS, while important, is not a guarantee of a regulatory compliant SDS. For a Language Service Company (LSC) to claim this form of “Regulatory Translation” is good, but the regulations governing formatting are not necessarily the same ones governing the translation of the various EHS phrases and terminology. Knowing which regulations to use, and where to find the correct phrase within those regulations, is quite different from formatting differences.

Another form of regulatory compliance is the actual content of the SDS and ensuring the warnings and phrases used within the datasheet are correct according to regulations, based on the chemical substances and quantities covered. The content form of compliance is best left to an experienced SDS author. Most translation companies are not staffed to do SDS authoring, just as most SDS authoring providers are not staffed to do translation.

A third form of regulatory compliance is the actual translation of an SDS from one language to another. SDS translations require a high level of familiarity with the official, translated EHS regulations worldwide. The LSC should be able to provide the source regulation for their SDS phrase translations in whichever language they appear. Correctly sourcing SDS translations is far more challenging than it may seem. In many instances, updates to a base regulation occur over time, and variations of the same phrase often appear within the same source document, but only one is actually compliant. H and P phrases are a good example as they are spread across several regulations, going from EC1272-2008 through EC918-2016.

Your SDS may be well-formatted, and technically compliant with all the necessary chemical warnings, yet still not meet strict compliance with the current regulation because the wrong reference or no reference supports the translated phrases. The correct sourcing of H and P phrases, UN Numbers, SDS section headers and sub-headers all require careful research. If you are unsure whether your LSC is sourcing their SDS phrase translations, simply ask them for a specific source regulation for each phrase they translate, even going as far as a page and paragraph number rather than a general reference to a single regulation.

If regulatory compliance is a key concern as part of your overall EHS program, then finding the right LSC to do your SDS translations is critical to your success. You invest heavily in sending your regulatory specialists to conferences and training seminars so they are up-to-date on all the changes that impact your hazardous substance classifications. Why risk the introduction of a regulatory error when it comes to having that SDS translated?

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