Are Your Safety Data Sheets Up To Date?
Providing accurate information to people who use, handle or store hazardous chemicals is paramount to workplace safety. Read on to make sure your SDSs are compliant with OSHA’s Hazard Communication Standard.
New chemicals used in an ever-widening variety of applications are continually being developed. Providing accurate, clear and concise information to people who use, handle or store hazardous chemicals is paramount.
On March 26, 2012, the Occupational Safety and Health Administration (OSHA) revised the Hazard Communication Standard, 29 Code of Federal Regulations (CFR) 1910.1200. The revision was effective 60 days thereafter, and a four-year phase-in period was incorporated.
One of the most significant changes in the revised standard is the adoption of the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This adoption provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards. The information required on the Safety Data Sheet (SDS), formerly referred to as a Material Safety Data Sheet (MSDS), has remained essentially the same. However, the revision requires the information on the SDS be presented using 16 specific headings in a specified sequence. 29 CFR 1910.1200(g) provides the heading information to be included and the order in which they are to be provided. 29 CFR 1910.1200 Appendix D provides the information to be included under each heading. The SDS format is the same as the American National Standards Institute Z400.1/Z129.1-2010 Hazardous Workplace Chemicals – Hazard Evaluation and Safety Data Sheet and Precautionary Labeling Preparation Standard format that is widely used in the U.S. and is already familiar to many.
Sections 1 through 8 of the SDS contain general information about the chemical, identification, hazards, composition, safe handling practices and emergency control measures. Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information and other information including the date of preparation or last revision. To be consistent with GHS, the SDS must also contain Sections 12 through 15: ecological information, disposal considerations, transport information and other regulatory information. OSHA does not enforce the content of these sections because they fall outside of its jurisdiction. A description of all 16 sections of the SDS, along with their contents, is given below:
Section 1: Identification
Identifies the chemical and the recommended uses. It also provides the supplier’s essential contact information. Required information consists of:
- Product identifier used on the label and any other common names or synonyms by which the substance is known
- Name, address and phone number of the manufacturer, importer or other responsible party, and emergency phone number
- Recommended use of the chemical, a brief description of what it actually does and any restrictions on use
Section 2: Hazard(s) Identification
Identifies the hazards of the chemical and the appropriate warning information associated with those hazards. Required information consists of:
- Hazard classification of the chemical
- Signal word
- Hazard statement(s)
- Precautionary statement(s)
- Description of any hazards not otherwise classified
- For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. This is a total percentage of the mixture and not tied to the individual ingredient(s).
Section 3: Composition/Information on Ingredients
Identifies the ingredient(s) contained in the product, including impurities and stabilizing additives. This section includes information on substances, mixtures and all chemicals where a trade secret is claimed. Required information consists of:
- Chemical name
- Common name and synonyms
- Chemical Abstracts Service (CAS) number and other unique identifiers
- Impurities and stabilizing additives, which are themselves classified and contribute to the classification of the chemical
- Same information required for substances
- The chemical name and exact percentage of all ingredients that are classified as health hazards and are:Present above their cut-off/concentration limits or
- Present a health risk below the cut-off/concentration limits
- The exact percentages of each ingredient must be specified, but concentration ranges may be used in the following situations:
- A trade secret claim is made
- There is batch-to-batch variation
- The SDS is used for a group of substantially similar mixtures
- Chemicals where a trade secret is claimed
- A statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret is required
Section 4: First Aid Measures
Describes the initial care that should be given by responders to an individual who has been exposed to the chemical. Required information consists of:
- Necessary first aid instructions relevant to the route(s) of exposure: inhalation, skin and eye contact, and ingestion
- Recommendations for immediate medical care and special treatment needed when necessary
- Description of the most important symptoms or effects and any symptoms that are acute or delayed
Section 5: Fire-Fighting Measures
Provides recommendations for fighting a fire caused by the chemical. Required information consists of:
- Recommendations of suitable extinguishing equipment
- Recommendations on special protective equipment or precautions for firefighters
- Advice on specific hazards that develop from the chemical during the fire; any hazardous combustion products created when the chemical burns
- Information about extinguishing equipment that is not appropriate for a particular situation
Section 6: Accidental Release Measures
Provides recommendations on the appropriate response to spills, leaks or releases, including containment and cleanup practices to prevent or minimize exposure to people, properties or the environment. It may also include recommendations distinguishing between responses for large and small spills where the spill volume has a significant impact on the hazard. Required information may consist of recommendations for:
- Use of precautions and protective equipment to prevent the contamination of skin, eyes and clothing
- Cleanup procedures/techniques
- Methods and materials used for containment
- Emergency procedures, including instructions for evacuations, consulting experts when needed and appropriate protective clothing
Section 7: Handling and Storage
Provides guidance on the safe handling practices and conditions for safe storage of chemicals. Required information consists of:
- Precautions for safe handling, including recommendations for handling incompatible chemicals, minimizing the release of the chemical into the environment and providing advice on general hygiene practices
- Recommendations on the conditions for safe storage, including any incompatibilities
Section 8: Exposure Controls/Personal Protection
Indicates the exposure limits, engineering controls and personal protective measures that can be used to minimize worker exposure. Required information consists of:
- OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) and any other exposure limit used or recommended by the chemical manufacturer, importer or employer preparing the safety data sheet, where available
- Recommendations for personal protective measures to prevent illness or injury from exposure to chemicals, such as personal protective equipment (PPE) and any special requirements for the PPE
- Appropriate engineering controls
Section 9: Physical and Chemical Properties
Identifies physical and chemical properties associated with the substance or mixture. Minimum required information consists of:
- Appearance (physical state, color, etc.)
- Flammability (solid, gas)
- Decomposition temperature
- Evaporation rate
- Auto-ignition temperature
- Flash point
- Partition coefficient: n-octanol/water
- Initial boiling point and boiling range
- Melting point/freezing point
- Relative density
- Vapor density
- Odor threshold
- Vapor pressure
- Upper/lower flammability or explosive limits
Every item listed above may not be relevant or available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties.
Section 10: Stability and Reactivity
Describes the reactivity hazards of the chemical and the chemical stability information. Required information consists of:
- List of any known or anticipated hazardous decomposition products that could be produced as a result of use, storage or heating
- List of all classes of incompatible materials with which the chemical could react to produce a hazardous situation
- List of all conditions that should be avoided
- Description of the conditions under which hazardous reactions may occur
- Indication of the possibility of hazardous reactions, including a statement as to whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous conditions
- Indication of any safety issues that may arise should the product change in physical appearance
- Description of any stabilizers that may be needed to maintain chemical stability
- Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled
- Chemical stability
- Description of the specific test data for the chemical(s). This data can be for a class or family of the chemical if such data adequately represent the anticipated hazard of the chemical(s), where available.
Section 11: Toxicological Information
Identifies toxicological and health effects information or indicates that such data are not available. Required information consists of:
- Information on the likely routes of exposure: inhalation, ingestion and/or skin and eye contact
- Indication of whether the chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs or found to be a potential carcinogen by OSHA
- This description includes the symptoms associated with exposure from the lowest to the most severe exposure
- Description of the symptoms
- The numerical measures of toxicity
- Description of the delayed, immediate or chronic effects from short- and long-term exposure
- The SDS should indicate if the information is unknown
Section 12: Ecological Information (non-mandatory)
Provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment. The information may include:
- Data from toxicity tests performed on aquatic and/or terrestrial organisms, where available
- Other adverse effects: environmental fate, ozone layer depletion potential, photochemical ozone creation potential, endocrine disrupting potential and/or global warming potential
- The potential for a substance to move from the soil to the groundwater
- Results of tests of bioaccumulation potential, making reference to the octanol-water partition coefficient and the bioconcentration factor where available
- Whether there is a potential for the chemical to persist and degrade in the environment either through biodegradation or other processes, such as oxidation or hydrolysis
Section 13: Disposal Considerations (non-mandatory)
Provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices. To minimize exposure, this section should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS. The information may include:
- Description of appropriate disposal containers to use
- Any special precautions for landfills or incineration activities
- Language discouraging sewage disposal
- Description of the physical and chemical properties that may affect disposal activities
- Recommendations of appropriate disposal methods to employ
Section 14: Transport Information (non-mandatory)
Provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail or sea. The information may include:
- UN number
- Any special precautions an employee should be aware of or needs to comply with, in connection with transport or conveyance either within or outside their premises
- Guidance on transport in bulk
- Environmental hazards
- Packing group number, if applicable, based on the degree of hazard
- Transport hazard class(es)
- UN proper shipping name
Section 15: Regulatory Information (non-mandatory)
Identifies any national and/or regional safety, health and environmental regulations specific for the product that are not indicated anywhere else on the SDS.
Section 16: Other Information
Indicates when the SDS was prepared or when the last known revision was made. The SDS may also state where the changes have been made to the previous version. Other useful information also may be included here.
SDSs are the backbone of the Hazard Communication Standard. They provide comprehensive and specific chemical information used not only by workplaces that manufacture, use, transport or store hazardous chemicals, but also by emergency responders, poison control centers and transporters of dangerous goods. The revised Hazard Communication Standard provides a single set of harmonized criteria for classifying chemicals and also stipulates specific hazard communication elements for SDS labeling, all in an effort to help improve the safety and health protections for America’s workers.
Commonly Asked Questions
Q: What are the major changes to the revised Hazard Communication Standard (HCS)?
A: The three major areas of change in the revised Hazard Communication Standard are in hazard classification, labels and safety data sheets.
- Hazard classification: The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures. These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a results
- Safety Data Sheets: Will now have a specified 16-section format.
- Labels: Chemical manufacturers and importers will be required to provide a shipped-to-container label that includes a harmonized signal word, pictogram and hazard statement for each hazard class and category. Precautionary statements must also be provided.
Q: The United Nations revises the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) every two years. How will OSHA communicate changes to the Hazard Communication Standard going forward?
A: OSHA anticipates that future updates of the Hazard Communication Standard may be necessary and can be done through various rulemaking options, including:
- Technical updates for minor terminology changes
- Notice and Comment rulemaking for more substantive or controversial updates such as additional criteria or changes in health or safety hazard classes or categories
- Direct Final Rules for text clarification
Q: What is the phase-in period for the revised Hazard Communication Standard?
A: The table below summarizes the phase-in dates required under the revised Hazard Communication Standard:
Effective Completion Date
December 1, 2013
Train employees on the new label elements and SDS format.
June 1, 2015
December 1, 2015
Comply with all modified provisions of the final rule, except:
All chemical manufacturers, importers, distributors and employers
June 1, 2016
Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
Comply with either the revised final standard, the current standard or both.
All chemical manufacturers, importers, distributors and employers
Q: When must the Safety Data Sheets be updated?
A: If the preparer of an SDS becomes aware of any significant new information regarding the hazards of the chemical or ways to protect against the hazards, then this new information must be added to the SDS within three months.
American National Standards Institute Z400.1/Z129.1-2010 Hazardous Workplace Chemicals – Hazard Evaluation and Safety Data Sheet and Precautionary Labeling Preparation Standard
United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS)
29 Code of Federal Regulations (CFR) 1910.1200