10 common Turkish SDS mistakes and how to check your SDS

1. A foreign emergency telephone number (Section 1)

An emergency number abroad, copied from the supplier's form, is of no use to a user in Türkiye. Section 1.4 must contain an emergency telephone number reachable from Türkiye, with its hours of service; for poisoning, the number of the National Poison Information Centre (UZEM, Ulusal Zehir Danışma Merkezi) 114 is also commonly added. Check: call the number outside office hours; does anyone answer?

2. Section 2 does not match the label

Writing "Danger" in the GBF but using "Warning" on the label, putting a pictogram on the label that is not in the GBF, or the reverse, is the first error caught in an inspection. Section 2.2 is an exact copy of the label elements. Check: put the label's print file next to Section 2.2 and compare them line by line. For the mandatory label elements, see What must a chemical label contain?

3. Forgetting the precedence rule

Adding the exclamation mark (GHS07) when the skull and crossbones (GHS06) is present, or adding GHS07 for skin irritation when corrosion (GHS05) is present, is common. CLP Article 26 removes these duplicates. In the same way, H318 is not written separately when H314 applies. The rules are in The 9 hazard pictograms.

4. A pile of P statements and withdrawn codes

Carrying every P statement from the assignment table onto the label and into Section 2.2 makes the label unreadable. The general rule is no more than 6 statements (CLP Article 28); response and prevention statements for the most severe hazard take priority. Another common error in old forms is withdrawn codes: P281 no longer exists and P280 is used instead. Check: enter your H codes in the CLP label tool and compare with the six suggested statements; withdrawn codes are marked in the code dictionary.

5. Skipping specific concentration limits and the M-factor (Section 3)

If a component's harmonised classification has a specific concentration limit (SCL) or an M-factor for the environment, the mixture calculation is done with these, not with the generic limits. Skipping the SCL classifies the mixture more leniently than it should be. In Section 3 these values should be shown next to the component. Worked example: Mixture classification under CLP.

6. Incomplete component identity (Section 3)

In Section 3, each hazardous component is given with its name, identifiers (CAS, EC and the registration number if there is one), concentration (exact value or narrow range) and classification with H codes. Generic names such as "surfactant mixture", rows without an identification number, and ranges that add up to more than 100% are common gaps.

7. Not giving Turkish exposure limit values (Section 8)

A Section 8 copied from a foreign form usually contains that country's limit values. In Türkiye, occupational exposure limit values are in the annex of the Regulation on Health and Safety Measures for Working with Chemical Substances (Kimyasal Maddelerle Çalışmalarda Sağlık ve Güvenlik Önlemleri Hakkında Yönetmelik); if the component is listed there, the value must appear in Section 8.1 together with its legal basis. For personal protective equipment, stating the material and thickness (e.g. nitrile, 0.4 mm) instead of "use suitable gloves" is also expected.

8. Filling Section 9 with "no data"

Basic properties such as appearance, odour, pH, flash point and density are known from the product itself or can be measured. If there really is no data for a field, "no data" is written, but the reason is also given (e.g. "not applicable to a solid product"). The flash point is especially important: it directly determines the flammability classification and the class 3 decision in Section 14.

9. Presenting component data as mixture data (Sections 11–12)

If the mixture has not been tested, Sections 11 and 12 give the data of the components, but they state clearly which component the data belongs to and its source. Writing a component's LD50 without a heading gives the reader the impression that it is the LD50 of the mixture. If an acute toxicity estimate (ATE) has been calculated for the mixture, it is stated separately.

10. Transport information that contradicts the classification (Section 14)

A mixture with H410/H411 in Section 2 that says "not dangerous goods" in Section 14, or a corrosive (H314) product that is not given class 8, are typical inconsistencies. The transport class does not follow from the CLP class alone (flash point and packing group criteria are separate), but the two sections must explain each other. Details: SDS Section 14: UN number and ADR.

A 5-minute check before release

• Section 2.2 = label (pictograms, signal word, H, P).
• Every H code in Section 3 is in Section 16 with its full text.
• The classification in Section 2 gives the same result when calculated from the components in Section 3.
• The flash point in Section 9 matches Section 2 (flammability) and Section 14 (class 3).
• Version and date on the first page are current; changed sections are listed in Section 16; the preparing KDU (Kimyasal Değerlendirme Uzmanı, certified chemical assessment expert) is named.

Most of these checks are about consistency between sections, and this is the most time-consuming part when done manually. Because Chemoris generates the sections from the same data, Sections 2, 3, 14 and 16 stay consistent by themselves; you can try it with a free account.

A printable tick-off version of this check for all 16 sections: SDS checklist (16 sections).

Frequently asked questions

Sources

• KKDİK Regulation (23/06/2017, Official Gazette No. 30105), Article 27 and Annex 2.
• CLP Regulation (EC) No 1272/2008, Articles 26, 27, 28; SEA Regulation (11/12/2013, Official Gazette No. 28848).
• Regulation on Health and Safety Measures for Working with Chemical Substances, Annex 1.
• ADR 2025, sections 2.1.3.10 and 2.2.9.1.10.