Precautionary Statements

1. What is the meaning of the forward slash (/) ?
• A forward slash (/) designates that the classifier can choose one of the precautionary statements. In the example, the label could state, “Do not breathe vapors or spray. Get medical attention if you feel unwell. Dispose of contents in accordance with local/regional/ national/international regulations.”
2. What is the meaning of three full stops (…) ?
• When three full stops (…) appear in the precautionary statement text, they indicate that all applicable conditions are not listed. For example, in "Use explosion-proof electrical/ventilating/lighting/.../equipment", the use of "..." indicates that other equipment may need to be specified. In such cases, the chemical manufacturer, importer, or responsible party can choose the other conditions to be specified.
3. What is the meaning of italics ?
• When text in italics is used in a precautionary statement, this indicates specific conditions applying to the use or allocation of the precautionary statement. For example, "Use explosion-proof electrical/ventilating/lighting/.../equipment" is only required for flammable solids "if dust clouds can occur". Text in italics is intended to be an explanatory, conditional note and is not intended to appear on the label. 
4. Is there a way to create custom Precautionary statements which replace the ...?
• Yes.  You can create one custom Precautionary statement for each P-code.  To create a custom Precautionary statement, go to File /  Customize P-statements 
• Any custom Precautionary statements will be become your default choice.
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5. Do I need to keep a precautionary statement if I think it is not applicable?  
• OSHA states" a manufacturer or importer may eliminate a precautionary statement if it can demonstrate that the statement is inappropriate. "
6. I have two phrases which include P330.  One is the combined P301+P330+P331 and also just P330 by itself.  Can I delete the P330?
• Yes.  Just highlight the row and press the "-" button.

Mixtures/Components and Formulations

1. How do I omit a substance from appearing on the SDS (e.g., if it is below a cut-off)?
• Click on the Omit row check box (see image below)
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2. How do I omit hazard information for a substance from appearing in SECTION 3: Composition/information on ingredients on the SDS?
• Click on the Omit haz check box (see image above)
3. How do I indicate a component is trade secret and hide its chemical name and CAS no?
• Click on the Name w/h check box (see image above).  When you generate the SDS, the actual component name will be replaced through out with Component 1 (trade secret)
4. How does OSHA define "trade secret" ?
• Click here to see OSHA's definition.
5. Once I have finished an SDS and discover a mistake in the ingredients section, how do I eliminate one of the ingredients listed?
• Highlight the row and press the delete (" –") button. 
• NOTE: If you have added hazard classifications or statements in Section 2 based on the presence of this component in your product, you should determine whether these classifications and statements should still be included.
  
6. How do I know if a component is classified or not?
• The GHS clas column in the component table (see image above) indicates the classification status of each component: is classified (Yes), is not classified (No), has yet to be determined (TBD).  You may need to go to the substance record to edit or add GHS classification information or to indicate that a substance is in fact not classified.  We have a video on the topic.
  
  

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7. How do I omit synonyms from being printed into a SDS?
• When you generate the SDS click on the "Don't print component synonyms" checkbox (see image below).
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• Alternatively you can delete the unwanted synonyms from the Common names(s)/synonyms(s) cell in the component table (see image at top of this section)
8. Do I need to list all components in Section 3? 
• Per 1910.1200(g)(2)(iii), all ingredients that are classified as health hazards and are present at or above their cut-off/concentration limit or present a health risk below the cut-off value/concentration limit must be listed in Section 3 of the SDS. 
• To determine applicable cut-off/concentration limits for each hazard class, consult Appendix A TO §1910.1200—Health Hazard Criteria (Mandatory)
• Several OSHA letters of interpretation may be helpful as well:  OSHA letter on Section 3 and cut-off concentrations and  OSHA letter on Section 3 and cut-off concentrations (2)
9. How do I find SDSs which contain a specific chemical by its CSA number?
• On the SDS browse list, click on [F]ind button
• In the Query window, click on the little arrow to the right of the empty text box and select CAS_number under SDS_component.  Select is and then type the CAS number of the chemical (see image below)
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10. Please tell me about your Formulator Wizard?
• Since it has been requested by many of you, we are very excited to announce our Formulator Wizard. We are sure it will save many of you countless hours of time. The Formulator Wizard saves you time especially when you are creating a SDS of a complex mixture. For example assume that you have 2 or more ingredients which you mix together in a certain ratio to create your product. And assume that each of these ingredients is itself composed of several chemicals. To determine the total amount of each chemical could require the use of a complicated spreadsheet. The formulator wizard will keep track of the amount of each chemical you add.  
• Upon purchase of the Formulator Wizard (list price $249) we will provide a license key which automatically turns on this functionality. 
• Please watch this video to see the Formulator Wizard in action:

• YouTube Video
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Substance Records

1. How do I find a Substance record (e.g., Acetone)?
• Select Substances from the File menu.  The Substance list will be presented.
• To list all of the over 75,000 substances, click on the All [J] button or press control + J on your keyboard
• To find a substance,  click on the [F]ind button or press control + F on your keyboard.  
• Select the parameter to search from the Find dropdown list.   It is preferred to enter the CAS# of the substance (see screen shot of 67-64-1 for Acetone in which CAS_number is selected from the dropdown list and 67-64-1 is entered in the text box)
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2. How to I go directly to a Substance record once I have added it as a component?
• While in the actual SDS, click on the S button and then choose List SDS components
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3. How do I edit the GHS classifications, Hazard statements, Precautionary statements etc of a substance?
• In the substance record, click on the Health tab.  
• GHS and other classification data is found in the Hazard summary table. Click on the column headings to sort or use the scroll bar. The GHS data is found under the categories: GHS classification, GHS hazard, GHS pictogram, GHS signal, GHS precaution
• Use either the Multi-select button or the GHS pulldown to add data to the table
• Use the - button to remove data from the table
• Remember to press the [S]ave button
  
  
  
  
  
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4. How do I edit toxicity data in a substance record?
• Please refer to Toxicity and Toxicity Data Sources.
5. How do I edit exposure limit data in a substance record?
• Please refer to Exposure Limits.
6. How do I find Substance records which contain a specific component?
• In the Substance list text bow located in the lower left corner, type "contains" followed by the chemical name or CAS to find substance which contain this chemical as a component.  In the example below we find Baypure CX-100 contains this component (Sodium fumarate dibasic with CAS 17013-01-3)
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Exposure Limits and PPE

1. Where do I find occupational exposure limits ?
• Table with OSHA and ACGIH values:  https://www.osha.gov/dsg/annotated-pels/tablez-1.html 
• Some background on OSHA and ACGIH values:
• US occupational exposure limits: OSHA 29 CFR 1910.1000 TABLE Z-1 LIMITS FOR AIR CONTAMINANTS
• Includes PEL and C and also skin. Read the footnotes at the end of the table. The units are in either ppm or mg/m3 
• Also refer to Tables Z-2 and Z-3 
• Note: OSHA Annotated Table Z-1 has been imported into SDScribe
• NIOSH Recommended Exposure Limts (REL) http://www.cdc.gov/niosh/npg/
• ACGIH “Threshold Limit Values (TLVs®) and Biological Exposure Indices (BEIs®)”
• These are ACGIH recommendations, not legally-binding standards. These data are available for purchase from ACGIH. 
• They include TWA, STEL, BEI
• https://www.acgih.org/Products/tlvintro.htm Page 11 of 16 version 4/23/15
• ACGIH “Workplace Environmental Exposure Levels (WEELs) ® 
• Occupational exposure limits (OELs) are developed for protection of healthy workers; they are not intended for the general public, which includes sensitive populations such as infants, the elderly, or the infirm. OELs are based on repeated daily exposures over a working lifetime. They are normally averaged over an 8-hour workday and serve to protect against acute and chronic health effects.
• In 2013 the development of Workplace Environmental Exposure Levels (WEELs) was transferred from AIHA to the Occupational Alliance for Risk Science (OARS) which is managed by Toxicology for Risk Assessment (TERA). AIHA will continue to post WEEL values on our website as they are updated by OARS. WEEL values are also posted to the TERA OARS website.
2. How are Exposure Limits entered into SDScribe?
• These are entered into the Exposure Level table of Substance record (see image below on left).  We recommend having these entered into the table before you actually add the substance component.  When you enter a component which has exposure levels into the component table of the SDS, the program will ask you if you want to import these into the exposure table of the SDS (see image below on right)
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3. (OSHA LOA 2013).  Section 8 of the SDS requires the SDS preparer to include the applicable OSHA permissible exposure limits (PELs) and American Conference of Governmental Industrial Hygienists (ACGM) Threshold Limit Values (TLVs®). Must the PELs and TLVs® be included regardless of the concentration of the constituent or ingredient? Are they required if the ingredient does not contribute to the hazard classification? If the material has a TLV® and must be listed in Section 8, does it also have to be listed in Section 3
• Under Section 8 of Appendix D to the HCS 2012, subheading (a), the manufacturer must list the OSHA PEL, ACGIH TLV®, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available. The requirement to include PELs and TLVs® in Section 8 of the SDS applies to any constituent or ingredient (including additives and impurities) that is present in the mixture or - substance above its cut-off value, or if it is below the cut-off value but still contributes to the hazard classification of the material. Please see the answer to question 8 for more details about contributing to the classification of the material. If a constituent is not present in the mixture or substance above its cut-off value, and does not contribute to the hazard classification of the substance or mixture, the PEL and TLV® associated with the ingredient need not be listed on the SDS. The lists of constituents in Sections 3 and 8 must be the same. If the constituent does not have a TLV® or PEL, its recommended exposure limit must be listed as "not applicable (N/A)" or "none."
4. What are "DERIVED NO EFFECT LEVEL" (DNEL)?
• The level of exposure above which humans should not be exposed. Used in REACH quantitative risk characterization and is established for the substance based on:
• Population: Workers, consumers and the general population (via environment)
• Route: Inhalation, dermal and ingestion exposure
• Duration: Acute (short-term) and chronic (long-term) exposure
• Effect: Systemic or local 
• Derived for chemicals having a threshold mode of action
• Potential for many different DNELs because of different combinations and exposures
• A very good summary of this topic is found here
• Another good summary is found here
• The GESTIS DNEL Database has some values
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5. In SDScribe 2016, I notice that there are optional PPE Pictograms which can be selected in tab 8.2 Exposure-protection.  Am I required to add these to my SDSs?  And how do I replace the PPE pictograms with my own in-house ones?
• You are not required to display PPE pictograms.   
• To replace the in-house versions with your own images, make sure the images have the same file name as the one that you want to replace (e.g., WP_gloves.jpg) and is located in this folder:  C:\Hazard_Solutions\Database\Resources\Graphics
• To re-size the images from 30-150 pixels, enter a value in the text box.  The default size if 48 pixels.
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Toxicity and Ecotoxicity and Data Sources

1. How do I enter toxicity and ecotoxicity data from a Substance record into my actual SDS?
• Populate the Toxicity table in the actual substance record with available toxicity data.  And then you can paste the actual value into the applicable text box in the SDS (e.g., Acute toxicity).  
• Please watch the video:

  YouTube Video
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2. How do I obtain toxicity and ecotoxicity data?
• SDScribe includes links to some governmental websites with such data (some links are also listed in QuickTips, pages 39-40).  ECHA also valuable information in its Brief Profiles. Some of these links have been programmed into SDScribe (although we cannot guarantee they will be maintained since they are controlled by others).  From the substance record, select the website you would like to go to.  The image below illustrates how to access the eChemPortal for Boron nitride (left image) and the OECD website for Boron nitride (right image).  The OECD portal provides access to a number of other sites.  
  
                  
• Data from these sites can be typed into the substance record itself.  See the example below for the Toxicity table in the substance record of glycerol.  The Toxicity table can be populated by either collecting relevant data from other reliable SDSs of the pure product or going to sources of data, such as these described above. 
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• Links to some sources are listed here:
  

  • TOXNET (U.S. National Library of Medicine), a resource for searching databases on toxicology, hazardous chemicals, environmental health, and toxic releases
  • GESTIS DNEL Database
  • GESTIS is the Information system on hazardous substances of the German Social Accident Insurance Sources of Derived No Effect Level (DNEL), etc. o For the registration of each substance under the European chemicals regulation REACH, manufacturers or importers have to quote assessment benchmarks on which the protective measures are based. Among these assessment yardsticks are Derived No-Effect Levels (DNELs). The REACH regulation defines them as exposure levels beneath which a substance does not harm human health. o Very good source of overall SDS data (i.e., physical data, toxicology and ecotoxicology with references listed) o Includes German Occupational Exposure Limits and RECOMMENDATIONS OF MAK-COMMISSION 
  • OECD eChemPortal
  • Household Products Database (US Department of Health and Human Services).  Can look up ingredients in common products
3. How do I know which resource to use?
• Within the US National Library of Sciences, here is a useful link.
• For animal toxicity: HSDB
• Developmental and reproductive toxicity TOXLINE® or DART®
• Ecotoxicity (source data.  HSDB summarizes data).: Ecotox database
• Finnish environmental properties database
• CCRIS database contains chemical records with carcinogenicity, mutagenicity, tumor promotion, and tumor inhibition test results. It was developed by the National Cancer Institute (NCI). 
• information on AMES test
4. Where do I add "Delayed and immediate effects and also chronic effects from short- and long-term exposure"
• You can consider adding the specific information in the applicable section (e.g., Skin corrosion/irritation) or perhaps under Additional information (Tab 11.3) 
5. What is the meaning of some of the experimental toxicity values (Wiki)?
• no-observed-adverse-effect level, NOAEL
• Lowest-observed-adverse-effect level, LOAEL
• Maximum tolerable concentration, MTC, LC₀; Maximum tolerable dose, MTD, LD₀
• Minimum lethal concentration, LC_min; Minimum lethal dose, LD_min
• Median lethal concentration, LC₅₀; Median lethal dose, LD₅₀; Median lethal time, LT₅₀
• Absolute lethal concentration, LC₁₀₀; Absolute lethal dose, LD₁₀₀
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Transportation Section

Stock Phrases and Templates

1. What is a stock phrase and how do I use it?
• A stock phrase is a commonly used sentence or group of sentences that you often use in a SDS.
2. How do access the stock phrase list?
• When clicked into a text box, press the Stoc[k] button or Ctrl + k on your keyboard. The stock phrase dialogue window will open.
  
  
  
  
  
• Here is a YouTube video
  
  

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3. How do I import my own stock phrases so they will appear in the stock phrase list?
• The stock phrase import is found in File / Utilities/ Imports / Stock phrases (see image below)
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  • This import reads a tab-delimited, UTF-8 text file on disk. The text file has four columns per row:
  • 1. Category of stock phrase (max 255 characters)
  • 2. Stock phrase (text)
  • 3. Field name (max 255 characters)
  • 4. Example use (text)
    
    
  • The import finds existing stock phrase records from the category and stock phrase text (the contents of the first two columns). When exactly one record is found, it will update the record with non-blank values in the third and fourth columns. If no record is found, the import creates a new stock phrase record.  The import is also capable of reading an earlier version of the import file, which contains only the first two columns. The two-column file never updates existing stock phrases.  Hazard Solutions may have provided a stock phrase import file. If so, it should be located in your "Imports" folder, which should be in the "Resources" folder, which is along this path:
    C:\Hazard_Solutions\Database\Resources\
    
    If you want to create your own stock phrase import file using a spreadsheet program, ensure that you save the file as tab-delimited text, with UTF-8 encoding. Do not insert carriage returns into the spreadsheet cells, or the field parsing will be incorrect.  If you press the OK button, the program will next prompt you to identify the location of the import file on disk. Or click on Cancel to stop, without importing any information.
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4. Do you have a stock phrase file that I can use as a template to enter my own stock phrases which I can upload?
• Here is a file https://sites.google.com/site/sdscribesoftware/StockPhrases_20150608.txt?attredirects=0&d=1
5. What is a “Relevant field name”?
• This is the name the database recognizes for each text field.  For example, the “Relevant field name” for the "If swallowed" text box in the First Aid tab, is "First_aid_ingestion".  
• In order for the database to reduce the stock phrase list down to those pertinent to the text field, you need to make sure you have properly populated the “Relevant field name” with the exact name recognized by the database
• The Stock Phrase window includes a dropdown list with the known “Relevant field name”.  Make sure this is properly populated when you add a new stock phrase.
  
  
6. What is a SDS template 

• SDS templates are like partially-completed safety data sheets, for a particular type of product. They can save you time because certain SDS sections will already contain information. You can convert an existing SDS into a template, or use an existing SDS as the basis for creating a template.

  To create a template, check the “Template” box in the upper left of the SDS that you wish to use as the basis for the template (Fig.18). Once created, a template will have a pale yellow background instead of the normal orange background of SDSs.

  NOTE: You can also create a template from the orange-and-white SDS browse list, by right-clicking on an SDS and selecting “Make template from SDS”, from the pop-up menu.

  

• The program will present a dialog, offering to clear information from particular sections of the SDS (Fig. 19). You would remove information in these sections if it pertains only to a particular SDS product, rather than to the generic class for which you are creating the template.
  To create the template while preserving the original SDS, click on the Duplicate SDS as a template button.
  If you wish to convert the existing SDS into a template without first making a copy, click on the Convert SDS to a template button. In this case, the original SDS will no longer exist in the program. If you checked any of the “clear” boxes on the dialog, then you will lose the information in those sections.

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• Later, when you click on the [N]ew SDS button on the SDS browse list, the program will offer to create the new SDS from a template (“New SDS from template” in the pop-up menu, Fig. 2, above). If you have fifteen or fewer templates in the SDS section, then you can select the template you want to use directly from the pop-up menu.

  Tip: Consider naming templates by the category of material to which they apply. For example, “Corrosive liquid” or “Irritating solid”. Products with similar hazards and physical states are likely to share common SDS information.  

7. How to import an SDS template
• File > Utilities > SDSs from another SDScribe file
  
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Labels (OSHA requirements / relationship to Consumer Products and Pesticides. Cosmetics)

1. Where do I find the requirements for preparing an OSHA compliant label?
• The OSHA requirements are found here.  
2. How do I create my own format of the label? 
• SDScribe provides the required text and pictograms in the Label tab of each SDS that you create in a standard 8.5 x 11 inch document upon pressing the "Generate label text" button.  For greater editing flexibility (e.g., to double column, etc), select File /Save as  and save it on your desktop as a Word document (.doc).  Use Word or your other favorite editor to edit it to your requirements or tastes.  
• View our Youtube videos on labels

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3. How do I create a basic GHS label?
• If you have already created the SDS using SDScribe, then click in Label tab and press the “Generate label text” button
• If you have not already created the SDS using SDScribe, but just wish to create a basic GHS label for your product, then enter the minimum information which includes:
• Product name (in Identification tab)
• (optional) CAS no, EC no, Formula (in Identification tab)
• Applicable GHS Class(es), Pictogram(s), Hazard and Precautionary statement(s) (in Hazard tab) or check off “Not a hazardous material” checkbox.
• You can edit the Precautionary statements as described in this FAQ or also delete unnecessary ones by pressing the [-] button to the left of the table
• Then click in Label tab and press the “Generate label text” button. 
4. Is a GHS label required on every product?
• Per OSHA, labels on shipped containers. The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged, or marked. Hazards not otherwise classified do not have to be addressed on the container. Where the chemical manufacturer or importer is required to label, tag or mark the following information shall be provided:
• Product identifier
• Signal word;
• Hazard statement(s);
• Pictogram(s);
• Precautionary statement(s); and,
• Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.
• FYI.  Hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified. 
5. What is the precedence of hazard information?
• OSHA has the following rules per APPENDIX C TO §1910.1200—ALLOCATION OF LABEL ELEMENTS (MANDATORY)

• C.2.1.1 If the signal word "Danger" is included, the signal word "Warning" shall not appear;

  C.2.1.2 If the skull and crossbones pictogram is included, the exclamation mark pictogram shall not appear where it is used for acute toxicity;

  C.2.1.3 If the corrosive pictogram is included, the exclamation mark pictogram shall not appear where it is used for skin or eye irritation;

  C.2.1.4 If the health hazard pictogram is included for respiratory sensitization, the exclamation mark pictogram shall not appear where it is used for skin sensitization or for skin or eye irritation.

• The program may provide a warning message if it appears that you have added an extra pictogram.  But it is up to you to delete it.   

6. How do I determine what, if any, signal word to include?
• The hazard category determines the applicable signal word (i.e., Danger or Warning or none).  So first classify the substance or mixture.  Here is a link https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10102 to OSHA’s guidance on assigning the signal word.  I also attached a screen shot (below) which illustrates the associated Signal word for eye damage/irritation hazard classes.  
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7. I am interested in knowing the size requirements for GHS labels.
• Note:  here is a link to a private company's website which provides some information that may be useful.  
8. Does OSHA have any guidance for labeling small bottles?
• Yes.  Read this letter of interpretation.
9. Does OSHA allow supplemental information (such as PPE icons, consumer product safety information, etc) on a label?
• Under certain circumstances.  Read OSHA's letter of interpretation (Question 1)
10. Are HMIS labels required under the GHS standard?
• No.  Per OSHA's brief on labeling, they could be included as supplementary information. 
11. Can you describe HMIS labels to me
• This link has some background
12. How do I add NFPA and HMIS labels to my SDS?
• First, populate Section Section 15.2 Regulatory with the applicable NFPA and HMIS ratings
• Next, go to the Build report and press the Generate SDS text (EN) button.  You can check off the NFPA-HMIS text only check box if you wish to display only the text.
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13. Are pesticides required to have GHS labels?
•  The EPA regulated pesticides and as of April 2016, has not adopted GHS for pesticide product classification and labeling. In most cases, GHS hazard statements and pictograms should not appear on pesticide product labels sold and distributed in the United States.  Here is some more information on the topic. 
• To search for approved labels click here.
14. I have a consumer product, what are the labeling requirements of this?
• SDScribe is a tool for authoring SDS and GHS labels.  Although it could be used to create consumer product labels, we can not provide any resources, assistance, guarantees, etc.  
• Here are some websites that may assist you in determining the labeling requirements for your consumer product
• OSHA letter of interpretation on additional labeling (such as consumer product) in relation to GHS required labels
• Federal Hazardous Substances Act (FHSA) Requirements (consumer products which are classified as hazardous household products)
• US CONSUMER PRODUCT SAFETY ACT
• US Consumer Product Safety Act Policy on tracking labels for children's products
• US Consumer Product Safety Act list of specifically regulated chemicals and materials
• US FDA Summary of Labeling Requirements (cosmetics)
• Canadian Guide to the Consumer Packaging and Labelling Act and Regulations
• FDA animal product labeling 
15. I have a cosmetic product, what are the labeling requirements of this?
• This can be complicated.  This is a link to the FDA cosmetic labeling guide
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Foreign Language License

1. Please tell me about your foreign language features in your product.
• Please watch this video for a basic understanding of how this works.

• YouTube Video
  
  
2. I have a foreign language license.  How do I select a language (e.g., Spanish) and build the SDS template in this language (including the Hazard and Precautionary Statement)?
   (see images below)
• Click on the "EN-English" drop down (upper right) and select the language.  Only those with an asterisk are available.
• Next select "Build NE report" from bottom right 
• Press the "Generate SDs text (NE) button.
• Note: Watch the above video to learn how to populate the text boxes.
  
  
           
3. How do I obtain an SDS which I created in English in a foreign language, such as Spanish or French?
• You could hire a technical translator experienced in translating SDS and have them do this for you. 
• We sell a foreign language license which can assist you by providing Section headings in certain foreign languages (French, Spanish and Italian).  Please ask us for pricing for other languages. We have other translation features in SDScribe(TM), which include: 

  1. A web browser interface to Google Translate, where the user can paste the English text in to be translated; and then the ability to put it back into the SDS.

  2. Paired (separate) fields for a non-English language, so that each SDS can be saved in both English and one non-English language. 

  3. H-statements, P-statements, and Signal Words in the EU languages, as well as some other non-English languages like Arabic and Japanese. These items appear in the "File (menu) -> Phrase translations" section. (However, the generate SDS function will incorporate them into an SDS on generation, unless the user has purchased a foreign language option.)

  The machine translation, guidance documents, and translated phrases are provided by others on the internet. Consequently, we cannot claim accuracy or suitability for an SDS. 

• Here is a short video demonstration showing the use of this feature.  
4. Are there any online translation sources?

1. What, if any guarantees, do you have in the accuracy of the foreign language text on SDS created using the foreign language add on?

• We are not able to make any guarantees regarding features of the SDScribe(TM), either in terms of accuracy or suitability for a particular task.   Section 5 of our end-user license contains the "no warranty" clause (copied below).  The translation which we offer as an option is the ability to generate the full SDS ("Build NE report" tab) with section and subsection labels in a non-English language. If the user has not purchased the option, then the "Generate SDS (NE)" button will only generate part of the SDS, as a demo of how the option works.  The European Chemicals Agency (ECHA) publishes a guide to producing SDSs ("Guidance on the Compilation of Safety Data Sheets", ECHA-15-G-07-EN), which is also available in the ~20 other EU country languages. We take the section labels in the non-English ECHA guides which are equivalent to the English, and substitute them into the SDS at the time of generation. These labels apply to generating the ECHA-format SDS.   The section and subsection labels on the UN-format SDS differ in total number, and in some cases have different wording. They appear in the UN GHS document (5th Edition, 2013), Annex 4 (Guidance on the Preparation of Safety Data Sheets).  We have not found UN Annex 4 in the same non-English languages as the ECHA document. Therefore, we make judgments about how the UN labels appear when we generate them in non-English languages.  In addition, there are items like "General hazard statement", "Printed on", "trade secret", "Page x of y", "No data available", "Supersedes", etc., which we must translate ourselves.  Because we have no proficiency in most of these languages, we make use of machine translation (Google Translate) for section labels and other items where a non-English equivalent is unavailable in the guidance documents.  We have other translation features in SDScribe(TM), which are included for all users (i.e., they are not options, but part of the basic package): 

  1. A web browser interface to Google Translate, where the user can paste the English text in to be translated; and then the ability to put it back into the SDS.

  2. Paired (separate) fields for a non-English language, so that each SDS can be saved in both English and one non-English language. 

  3. H-statements, P-statements, and Signal Words in the EU languages, as well as some other non-English languages like Arabic and Japanese. These items appear in the "File (menu) -> Phrase translations" section. (However, the generate SDS function will incorporate them into an SDS on generation, unless the user has purchased a foreign language option.)

  The machine translation, guidance documents, and translated phrases are provided by others on the internet. Consequently, we cannot claim accuracy or suitability for an SDS. 

  For any SDS to be provided in a non-English language, we strongly encourage the user to have it reviewed by a native speaker or a professional translator. Where products are destined for EU countries, the ECHA requires that a non-EU producer have a distributor in the destination country. The in-country distributor is ultimately responsible for the accuracy of the SDS.
  
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  5. No Warranty. The Software is being delivered to you AS IS. Hazard Solutions, LLC makes no warranty as to its suitability for any particular use, or for its performance. Chemical manufacturers and distributors are ultimately responsible for the accuracy of the Safety Data Sheets representing their products, and the Software cannot assume this role.
  
  Hazard Solutions, LLC AND ITS SUPPLIERS DO NOT AND CANNOT WARRANT THE PERFORMANCE OR RESULTS YOU MAY OBTAIN BY USING THE SOFTWARE OR DOCUMENTATION.  Hazard Solutions, LLC AND ITS SUPPLIERS MAKE NO WARRANTIES, EXPRESS OR IMPLIED, AS TO NONINFRINGEMENT OF THIRD PARTY RIGHTS, MERCHANTABILITY, OR FITNESS FOR ANY PARTICULAR PURPOSE. IN NO EVENT WILL HAZARD SOLUTIONS OR ITS SUPPLIERS BE LIABLE TO YOU FOR ANY CONSEQUENTIAL, INCIDENTAL OR SPECIAL DAMAGES, INCLUDING ANY LOST PROFITS OR LOST SAVINGS, EVEN IF A HAZARD SOLUTIONS REPRESENTATIVE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, OR FOR ANY CLAIM BY ANY THIRD PARTY.  Some states or jurisdictions do not allow the exclusion or limitation of incidental, consequential or special damages, or the exclusion of implied warranties or limitations on how long an implied warranty may last, so the above limitations may not apply to you.
  
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