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December 16, 2013
The MSDS and SDS conundrum
By Ana Ellington, Legal Editor

The Occupational Safety and Health Administration’s (OSHA) Globally Harmonized System of Classification and Labelling of Chemicals (GHS) revisions to the hazard communication standard (HazCom) have been in effect since May 2012, including a 3-year phase-in period that manufacturers, importers, and distributors will have to switch the material safety data sheets (MSDSs) to the new safety data sheets (SDSs) format. Many employers are now facing a two-part conundrum concerning the ongoing transition from MSDSs to SDSs in their workplaces:

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  1. How to manage the data sheet filing and employee access system when there are both MSDSs and SDSs for workplace chemicals; and
  2. How to train employees to understand both the new SDS and the old MSDSs during the transition.

Because HazCom 1994 did not establish a uniform format, there are currently a number of different MSDS styles and formats in use in the United States. HazCom 2012, on the other hand, mandates the use of a universal GHS format for the SDS, a format that is a strict 16 sections. In short, the format is being standardized for ease of training and notification of hazards. However, during the 3-year phase-in period to HazCom 2012, you should expect your MSDS library to have a mix of non-GHS formatted—or MSDSs—and the GHS-formatted SDSs until the phase-in is complete when the chemical manufacturers, distributors, and importers have reclassified all of their chemicals using the GHS criteria. Many chemical manufacturers, importers, and distributors will be making the shift to the GHS-compliant SDSs in stages—they have until June 1, 2015 (distributors have until December 1, 2015).

The first HazCom 2012 deadline was December 1, 2013, when more than 5 million U.S. workplaces should have trained their employees on the new label elements and the SDS format. This may be confusing for a while because for the next 30 months, some workplaces may not even see a GHS-compliant SDS.

Managing the MSDS and SDS

Develop a plan. What OSHA expects is that you have a plan in place to ensure that as updated SDSs come into your organization, they are handled properly. This means having a management system in place comparing the new SDSs to the old ones to see if there are any new hazards that employees need to be trained on to understand what they are working with and ensuring the updated documents are made available to employees in a timely fashion. Now HazCom 2012 is not only the right-to-know rule but also the right for your employees to understand the hazardous chemicals with which they work and how to safely handle them. There is no requirement to keep the old MSDSs once you receive an updated SDS to replace it. But keeping an electronic archive is a good idea. An electronic system can also simplify the transition.

Perform an inventory of the chemicals in your workplace. This will not only save you time in updating for chemicals no longer present, but will ensure you have up-to-date MSDSs/SDSs for all the chemicals in your workplace to which your employees are exposed. The latest SDS for each hazardous chemical must be made available in the workplace; all your employees must be able to access SDSs at all times. This means a supervisor’s permission is not required, and the SDS access management system is always functional.

The chemical manufacturer, importer, or employer preparing the SDS is responsible for the accuracy of the information provided on their SDSs. The preparer must ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification. Employers that rely on SDSs supplied by a manufacturer, importer, or distributor are not liable for their accuracy as long as they have accepted the SDS in “good faith”, that is, without blank spaces or obvious inaccuracies. You should report inaccurate or missing information on an SDS to the chemical manufacturer or distributor.

For employers that do their own evaluation or classification of a chemical, OSHA will hold them responsible for the accuracy of the SDS.

MSDS and SDS employee training

Train your employees. Along with labels on containers, and SDSs, employee training is one of the three core components of a comprehensive hazard communication program. Remember that under HazCom 2012, your employees not only have the right-to-know but also the right to understand the chemicals in the workplace and how to handle them safely. Training is needed to explain and reinforce the information presented in the SDSs to ensure that your employees understand the chemical hazards in their workplace and are aware of the protective measures they need to follow. Creating an effective HazCom 2012 training program may actually be easier than before because of the standardized format of the SDS that may improve hazard communication overall.

As part of the training, your employees must understand the standardized headings and sequence of information on SDSs. Although written information is important, training is an opportunity to explain the information on the SDS and helps to ensure that the messages are being received accurately.

To ensure employee understanding is effective, train on MSDS and SDS formats as long as you have MSDSs. Keep in mind that because there is a 30-month transition period, if you have MSDSs in your workplace, you must include training on those MSDSs in your training program. We are not aware of any statement from OSHA to stop training employees to interpret the old MSDSs if they are still used in the workplace. Nevertheless, your employees need to know the SDS universal format.

Although the transition may seem overwhelming at first, creating and following a plan for your GHS transition will make the process more successful.

The new SDS

When the SDSs begin to show up at your workplace, they will all follow this universal 16-section format that should make it easier for you to better know the physical and health hazards of the chemicals used in your workplace; to understand safety practices; and to train your employees.

The 16 sections in an SDS are required in the following order with the following headlines:

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 and any other pertinent information.

*Note: Since other agencies regulate this information, OSHA will not be enforcing Sections 12 through 15 (29 CFR 1910.1200(g)(2)).

Infographic: Hazard Communication and GHS
What comes next?
OSHA announces 2014 regulatory priorities. Are you ready?
GHS Training Infographic
Are you ready for the December 1 deadline?
HazCom’s first compliance date is December 1.
Do your workers understand?
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