by Andrew Reich
Protecting consumers against unsafe chemicals in products is one of the core responsibilities of suppliers, importers, and retailers. However, for new and old businesses alike, it is a constant challenge to stay on top of industry standards and legal requirements.
There are multiple kinds of documents and services available when it comes to information-gathering and testing for chemicals, all with different purposes. Here is a quick rundown of the more common types:
A SVHC Test (for “Substances of Very High Concern”) screens a sample of a product for any of the chemicals in the European Union’s unified list of SVHC chemicals, which are subject to regulation under the European Union’s REACH laws. This is a great place to start for importers who sell in Europe.
A CMR Test (for substances that are “Carcinogenic, Mutagenic, or Hazardous for Reproduction”) screens a sample of a product for a list of chemicals considered to be CMR. Unlike the list for a SVHC test, the list for a CMR test is not standardized by a government, and can instead be customized to suit specific product categories, countries of sale, claims made on retail packaging, etc. This mix-and-match approach is appropriate to test products for sale in countries such as the US, where regulations (e.g. FDA regulations, California Proposition 65 regulations, etc.) are not necessarily unified into any one list.
For both SVHC and CMR tests, the testing lab generally does not need to be provided with a list of materials in a product in order to screen it for the listed chemicals. These tests are useful for importers whose suppliers will not share ingredient lists with them, or who do not trust that the ingredient lists provided by their suppliers are accurate. But even if you do trust the supplier, it is still a good idea to carry out these tests – you never know what your supplier may have put in your products – and even your supplier does not necessarily know what their sub-suppliers put in their products.
A Toxicological Risk Assessment (TRA) contains information on whether substances are irritants or toxins in the concentration they appear in your product. This is especially critical for consumables and skin-contact products, including food and food packaging, cosmetics, toys, etc. A good TRA considers not only the substances’ own toxicity, but also their potential toxicity when mixed together in your product. A TRA can be used as a starting point for deciding whether your product would be legally allowed in certain countries’ markets, and what warning labels are required.
A Material Safety and Data Sheets (MSDS) (also known as Safety Data Sheet (SDS), or Product Safety Data Sheet (PSDS)), is a document with information on a chemical, including potential dangers, safe use, transport, handling, and disposal practices. An MSDS may also contain very general info on whether regulations exist against the listed chemicals in certain countries. Having an MSDS on file for all of the chemicals used in a workplace is part of basic workplace safety.
In contrast to SVHC and CMR tests, in which testing labs test physical samples for the presence of chemicals, TRA and MSDS documents are not results of actual testing. Instead, they rely solely on a list of ingredients, usually provided by the supplier, and are only as accurate as the list of ingredients is. Because of this, neither a TRA nor an MSDS is a guarantee that your product is free from a specific chemical. In short, SVHC and CMR tests on samples from production runs help to ensure that the products you are selling do not contain regulated chemicals. A TRA is a diagnostic tool to help you evaluate whether potential products are safe and legal to sell in certain markets. And an MSDS is a safety guide for a chemical that is found in a workplace.
However, these four services just brush the surface of chemical information-gathering and testing, and it is highly recommended to work through an established, independent lab on this. Often, these labs can provide valuable advice on testing programs tailored to your specific products and country of sale, in addition to doing the actual tests for you.
Good luck, and happy testing!