Based on an unofficial analysis of the chemical supply chain — MSDSonline now believes that perhaps as many as 65% of SDSs in the U.S. marketplace have been updated to the GHS format. This is a major shift from MSDSonline’s own findings in April and May of 2015, which showed at the time that less than 50% of SDSs were in compliance with GHS requirements.
Included within this 65% range are some chemical manufacturers that are 100% compliant, some that are 0% compliant, and a majority of which that are somewhere in between. This latter group is currently working through their chemical inventories and have a mix of both compliant and non-compliant safety data sheets in their libraries.
This shift confirms that a significant number of chemical manufacturers waited until the deadline to convert their safety data sheets; and that, overall, companies have gotten more serious about conforming to OSHA's revised HazCom Standard.
As most readers of this blog will know, the transition to GHS involves key changes to the formatting of the safety data sheets that are intended to create uniformity and quicker access for workers to important hazard information. These changes include a prescribed 16-section format, the inclusion of health and physical hazard based on OSHA’s adopted GHS criteria, and the use of signal words, hazard statements, pictograms, and other elements that overlap with new chemical label elements and format.
As OSHA and Health Canada gradually phase-in their adoptions of GHS, a period of “churn” has been created in which many businesses will see a big influx of newly formatted SDSs. During this time, employers should be prepared to manage a safety data sheet library that contains a mix of safety data sheets in both older and newer formats.
In the United States, as of the June 1, 2015 deadline, chemical manufacturers must begin providing newly formatted SDSs with their chemical shipments. However, manufacturers are still only required to provide new SDSs to their users:
- With initial shipments of chemicals
- With the next shipment after an SDS has been updated
- When requested by downstream users
MSDSonline recommends businesses take proactive steps during this period to ensure that their SDS libraries are as up-to-date as possible.
If you receive a chemical shipment going forward without an the updated SDS, or one that is incorrect, inadequate, or non-compliant, you may need to request an updated one from your supplier. (If your upstream request does not result in an adequate SDS, it’s also okay to contact your local OSHA office for assistance in getting the right SDS.)
It is vital during this period of change that your employees have the chemical hazard information necessary to work safely.