For decades, the material safety data sheet (MSDS) has been the back-bone of OSHA’s Hazard Communication Standard (HCS). As most safety professionals know by now, the Hazard Communication Standard has been revised by OSHA to align with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), the result of which will include substantial changes to the MSDS.
Note: OSHA is referring to the pre-revision HCS as HazCom 1994, and referring to the post-revision HCS as HazCom 2012.
What is an MSDS?
Before we dive into the changes, let us first answer the question, “What is an MSDS?” MSDSs are documents, normally many pages long, that travel with or ahead of hazardous chemical shipments, warning users of the specific dangers of such products and guidance on their safe handling, storage and disposal. Evaluating chemical hazards and producing MSDSs and labels for downstream users are two of the key responsibilities chemical manufacturers and distributors have under the HCS.
Maintaining an MSDS for every hazardous chemical and making them available to employees as part of the HCS’s Right-to-Know provisions – which says employees have the right to know about the chemicals to which they are exposed – is one of five key responsibilities employers have under the HCS. The other four key responsibilities employers have are:
- Maintaining a hazard communication program detailing the plans in place for the safe handling of chemicals
- Maintaining a written chemical inventory of every hazard chemical in the facility to which employees are exposed
- Maintaining proper labels and warning signs associated with said chemicals
- Training employees on chemical hazards and necessary precautions
An SDS is an MSDS
Based on the MSDS provisions in HazCom 1994, there are currently a number of different MSDS styles and formats in use in the United States, the most common being the 8 section OSHA MSDS and the 16 section ANSI standard MSDS. OSHA’s adoption of GHS via HazCom 2012, on the other hand, mandates the use of a single GHS format for safety data sheets, a format which features 16 sections in a strict ordering.
Another change, thanks to GHS, is the renaming of material safety data sheets from MSDSs to simply safety data sheets, or SDSs.
Unfortunately, this dropping of the M has caused more consternation than is warranted. The truth is, an SDS is an MSDS, they are really the same thing, especially in terms of the role they play in the HCS. In fact, the GHS SDS format is nearly identical to the ANSI Standard 16 section MSDS – with a couple of modifications.
One question a number of safety professionals have asked is, “Will we have to have two safety data sheet libraries – one for MSDSs and one for SDSs?” The answer is no. During the transition to HazCom 2012, employers should expect their MSDS library will have a mix of non-GHS formatted and GHS formatted safety data sheets until the transition is complete and chemical manufacturers have reclassified all of their chemicals using GHS criteria and updated all of their chemical documents.
However, employers should expect and prepare for all of their MSDSs to be replaced with GHS formatted SDSs in the next couple of years. For employers with hundreds or thousands of chemicals, or many facilities with lots of binders…this will likely be a major undertaking. Employers should also consider how they would like to handle the outdated safety data sheets.
While there are no provisions in HazCom 2012 that require the archiving of older MSDSs, it is a best practice that can be easily done using an electronic system. In fact, an electronic system will make the entire switch over to HazCom 2012 easier.
What Are the 16 Sections of an SDS?
As mentioned above, the GHS formatted SDS has 16 sections as follows (source: OSHA SDS Quick Card):
Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.
Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.
Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.
Section 8, Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
Section 9, Physical and chemical properties lists the chemical’s characteristics.
Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.
Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
Section 12, Ecological information*
Section 13, Disposal considerations*
Section 14, Transport information*
Section 15, Regulatory information*
Section 16, Other information, includes the date of preparation or last revision.
*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).
Additional information on the use of GHS formatted SDSs in HazCom 2012 is available in Appendix D of the HazCom 2012 regulatory text.
How to Manage the Transition to HazCom 2012
The bulk of the heavy lifting during the transition to GHS belongs to the chemical manufacturers and distributors. However, employers have a few key obligations related to SDSs that they will need to stay on top of. The good news is that with a solid strategy in place, employers should be able to not only maintain compliance, but also make considerable improvements to their HazCom Programs.
The first thing employers should do is make sure they understand the compliance deadlines laid out under HazCom 2012. There are four key deadlines:
- December 1, 2013 – By this date, employers must train employees on how to read GHS formatted labels and SDSs. Changes to labels are probably more substantial, however, employees need to understand where to find information on the SDS, especially in section 2 where critical hazard information is located.
- June 1, 2015 – By this date, chemical manufacturers and distributors should have completed their reclassification of chemicals and be shipping GHS formatted SDSs and labels with their shipments. By this time too, a majority of your library will have turned over.
- December 1, 2015 – Distributors have an additional 6 months beyond the June 1, 2015 date to pass along manufacturer labels and SDSs in the older formats. However, beyond December 1, 2015, all SDSs and labels in the U.S. should adhere to HazCom 2012 provisions.
- June 1, 2016 – By this date employers should be fully compliant with HazCom 2012. That includes making any necessary updates to their HazCom program, training employees on any newly identified chemical hazards (identification of new hazards is likely during the reclassification process chemical manufacturers undertake), and updating safety data sheets libraries and secondary labels.
Looking at the deadlines, one key obligation that employers have, which hopefully jumped out for you, is that incoming SDSs will need to be checked against the older MSDSs to see if there are any new hazards or precautions. Why? It’s likely that some of the chemicals you’ve used for years, on which all of your employees have already been trained, will by the end of the transition have new hazards or changes to handling recommendations that will require updated training. As you know, employees must be trained on all of the hazards of the chemicals to which they are exposed.
To comply, it will help if you have a system in place for catching new changes to safety data sheets. For example:
- Have a designated employee in charge of the transition to GHS
- Make sure your employees, especially those on the front lines in procurement and the loading dock (where MSDSs are likely to first enter the facility), are on the lookout for updated SDSs
- When a new safety data sheet comes in – have a system in place for comparing it to the earlier version, making note of any relevant changes
- Plan/execute training
- Update your MSDS library / archive old MSDS
As mentioned earlier, an electronic MSDS management system can be a great resource during this time. A great system gives easy access to millions of MSDSs and tools for managing them; flags SDSs in the GHS format; kicks out inventory reports; offers container tracking across the facility with mobile barcode scanning; checks chemicals and ingredients against various hazardous substance lists; provides chemical banning and approval tools, is sustainable, cloud-based, and has a high ROI paired with a low cost of ownership.
Going forward, whether called an MSDS or an SDS, safety data sheets will continue to be the back-bone of HazCom compliance. What you do now to prepare for the document churn will likely set the table for success or frustration over next several years. Big changes are coming, but that doesn’t mean it has to be a big problem.