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From MSDS to SDS – GHS Brings Big Changes to Safety Data Sheets in HazCom 2012

Aug 20, 2012

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:

  1. Maintaining  a hazard communication program detailing the plans in place for the safe handling of chemicals
  2. Maintaining a written chemical inventory of every hazard chemical in the facility to which employees are exposed
  3. Maintaining proper labels and warning signs associated with said chemicals
  4. 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:

  1. Have a designated employee in charge of the transition to GHS
  2. 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
  3. 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
  4. Plan/execute training
  5. 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.

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  16. Anika Burris | May 31, 2016
    Public patience with irresponsible companies has grown thin, especially for those unable to quickly and concretely convey the exact nature of the hazards associated with the chemicals in their charge. Because of the cases like the ones listed here, agencies like the EPA and OSHA are gaining regulatory leverage. For companies that use chemicals, the days of guessing are over. 
  17. Steve Perske | Mar 08, 2016

    Hello,

    We import chemicals from Germany for our machines , lubricants and coolants. Are they responsible for providing the updataed SDS sheets? How do they get past the customs if they don't have the required SDS information. This is a problem because when we resell the product our customers want an OSHA compliant SDS sheet.

  18. Tania Gonzalez | Feb 11, 2016

    Changing MSDS to SDS is going to cause a lot of confusion for biochemistry, chemistry, genetics, and molecular biology labs where SDS is also the abbreviation for an extremely common detergent. The abbreviation "SDS" is so common that there are students who don't know that it's long name is "sodium dodecyl sulphate." 

    How do I find the SDS for SDS on Google? It's a useless search unless you know more about the material's properties. Searching "SDS sodium dodecyl sulphate" also won't work. What about searching "SDS acrylamide"? I am more likely to get instructions on how to make an SDS-PAGE gel for electrophoresis than I am to find information on the dangerous neurotoxin (acrylamide).

    This is a terrible idea. Change it back to MSDS. The 4 letter acronym is much easier to use for targeted web searches than the new 3 letter acronym. Physical binders aren't the solution for this problem either. In emergency situations, it is not a good idea to limit a person's access to safety information to physical binders.

  19. Lynds | Jan 20, 2016
    I was wondering, when I am updating my MSDS binder to a SDS binder can I toss the old MSDS that I have updated in my binder or do I have to save them? 
  20. Denis Gregory | Jan 14, 2016

    Annoyingly, we use the chemical SDS (sodium dodecyl sulphate), an anionic surfactant, in our industry.  I'm a bit reluctant to call it NaDS, so I guess we will have to start calling it SLS.  

    I also think using the 'M' part of MSDS is clearer, as it tells us that the Safety Data Sheet alludes to a material.  You could have safety data about lots of other things.

    Oh well we'll get used to it.

    Denis

  21. Lou Koenig | Dec 08, 2015
    Is there a required size or minimum size of pictograms on SDS?
  22. Jeremy Eastham | Nov 18, 2015
    Do SDS sheet have to be printed in color or can they be printed in black and white and placed in binder for employees to view when needed?
  23. QA Bee | Nov 13, 2015

    Do labels also have to be converted in to new SDS format?

    Also, are the labels to be printed on color printer (Pictogram)? Or black & white printer should be fine.

    Thanks

  24. Answerman943 | Nov 12, 2015

    Cheryl. The short answer is yes, the long answer is all chemicals are hazardous and if a company has an MSDS for the item it is required to be updated to match the current criteria for safety reason. An individual affected by a hazard needs to find the fix as soon as possible and the fasted way to do that is to have the information in the same location on all data sheets.

  25. Answerman943 | Nov 12, 2015
    Julie. MSDS and SDS are the same thing, granted one system is newer than the other. You can have MSDS and SDS forms in the same book as long and you are replacing the MSDS forms when their SDS equivalent is available. Definitely update all forms to SDS before 1 June 2016.
  26. Answerman943 | Nov 12, 2015
    Paul. That may be something to send up the chain or hierarchy, it hasn't been addressed until your question. I am sure we will have a final answer for that before 1 June 2016.
  27. Anserman943 | Nov 12, 2015
    Tom. We are not required to follow GHS. we are required to follow OSHA. GHS is a United Nations concept to globalize standards. I do not know whether OSHA voluntarily adopted the concept or if it a presidential mandate, but we still have to follow OSHA's safety standards.
  28. Answerman943 | Nov 12, 2015

    Marie. Although you can store the PDF's on a CD or computer, the purpose of the binder is to give the individual hurt or his or her coworker the information as fast as possible to prevent delays or reduce chemical side-effects.

  29. Cheryl Garretson | Oct 26, 2015

    If a chemical is non-hazardous is the supplier responsible to update the MSDS to the new sds format?

    Thank you kindly,

  30. julie | Oct 19, 2015
    Must the SDS Sheets be kept in a seperate binder than the MSDS sheets?  I am also Scanning a copy electronically.  
  31. Paul Hamilton | Sep 25, 2015
    I was wondering if Section 16 should have the new GHS number system or is the HMIS system acceptable?
  32. bharbaugh | Aug 26, 2015

    Pam,

    It is up to the chemical manufacturers, importers, and distributors to update the safety data sheets. It is completely possible that the MSDSs for the products you're dealing with do not have updated SDSs yet. In the even that the new SDS does not yet exist, then OSHA would not hold you the end-user responsible for the lack of an update. That said, if you have received a shipment of a hazardous chemical after June 1, 2015 for which you do not have an updated safety data sheet, then it would be proper to reach out to the supplier and request one. If none is available, then you would want to document your effort and if you need help, reach out to your local OSHA office. Chemical manufacturers are not responsible for sending you an updated document if you have not ordered a new shipment since June 1, 2015. They do have to provide an updated document upon request (independent of a new order).

    Tom,

    If you look at Appendices A, B, and C of the revised Hazard Communication Standard, you will find the information you need to classify health and physical hazards under the GHS aligned HazCom Standard. https://www.osha.gov/dsg/hazcom/ghs-final-rule.html

    Marie,

    Yes, MSDSonline provides mobile and cloud access to safety data sheets. In addition, we make it easy to back up your library to a disc, flash drive, computer, etc.

  33. Pam | Aug 21, 2015

    I was printing out the MSDS Sheets when I realized they do NOT have the new requirements? Where can I find the SDS Sheets for 2015 with the hazard signs?

    Thank you

    Pam

  34. Tom Richardson | Jul 30, 2015

    Are there any charts or databases that convert OSHA hazard identifications to GHS Identifications?

    It'sone thing to say that OSHA is compliant to GHS, but if no one is able to translate one to the other, whats the point?

  35. marie romano | Jul 27, 2015

    I am not sure but hope you can help me i wanted to know if there is any other way

    to put togethere a sds library besides the binder maybe a cd disc or something we

    can set up for an easy way to get to it please advise   marie

     

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