What should a safety data sheet contain?
- Section 1: Identification of the substance or mixture.
- Section 2: Hazard(s) identification.
- Section 3: Composition and information on ingredients.
- Section 4: First-aid measures.
- Section 5: Firefighting measures.
- Section 6: Accidental release measures.
- Section 7: Handling and storage.
- 1 Can I write my own SDS?
- 2 Are SDS sheets free?
- 3 What is SDS template?
- 4 What is SDS cost?
- 5 Are SDS used internationally?
- 6 How many sheets does SDS have?
- 7 Are electronic copies of SDS sufficient?
Can I write my own SDS?
What items or formats are required on an SDS? It depends where you live. Each country has their own rules and regulations. For non-U.S. countries see the International section of this FAQ as well as our SDS Hyperglossary entry on the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), a format which is being adopted by many industrialized countries.
The US adopted the GHS format for SDS’s with its most recent revision of the OSHA Hazard Communication Standard (HCS 2012). Appendix D of the standard lists the minimum required elements as well as the required formatting described in paragraph (g) of the Standard, Prior to HCS 2012, OSHA had no format requirement of any sort.
It only required that (a lesser amount of) certain information appear on the MSDSs (SDS did not become the preferred term until OSHA adopted the GHS in 2012). In 1985, OSHA issued a suggested format called OSHA Form 174 (OMB #1218-0072) which defined eight main headers and was a useful template for MSDS authors.
As companies began complying with the original 1984 Standard, some began adding additional information to their MSDS’s such as toxicological and regulatory information (information that was becoming required in other countries), and MSDS’s began to vary widely in their content and format. Strictly speaking, there was nothing keeping a company from issuing an MSDS as a haiku if they wanted to.
OSHA was unable to enforce a required format without enacting changes to federal regulation, and formatting was, alas, omitted from the 1994 version of the HazCom Standard, In 1993, the American National Standards Institute’s (ANSI) published “Hazardous Industrial Chemicals – Material Safety Data Sheets – Preparation, ANSI Z400.1-1993” which promulgated a 16-part standard format and content, and this format quickly gained widespread international use and acceptance – so much so that OSHA quickly started recommending the ANSI format over Form 174.
- The ANSI standard was obviously incorporated into the GHS which was being developed around that time.
- Full implementation of HCS 2012 took effect June 1, 2016 in the US, and GHS-formatted SDS’s are now required with new shipments of chemicals,
- Still, your current collection may contain older MSDS’s that do not meet the current format.
Not to worry – there is no need to go through your collection and find SDS’s for materials received prior to June 1, 2015 – but as you receive new shipments of those older materials, you will need to update your SDS collection with the new sheets just as you always have,
- What do these terms or abbreviations on my SDS mean? Simply visit our searchable SDS HyperGlossary with explanations of hundreds of terms.
- Or, copy and paste your sheet into our MS-Demystifier and it will create a hyperlink entry for every term it recognizes in your SDS! According to a 1997 OSHA-contracted study, “on average, literate workers only understood about 60% of the health and safety information on the MSDSs associated with the hazardous chemical, in all three comprehensibility studies.” Is there a unique identification code for each chemical? Yes, Chemical Abstracts Service (CAS) Numbers are the most definitive identifiers, as each is unique and there are now over 114 million entries in the registry.
Prior to adoption of HCS 2012 neither CAS numbers nor other unique identifiers were required content on SDS’s. Per paragraph (g)(2)(iii) of HCS 2012 and as explicitly stated in Appendix D, section 3(c), SDS’s must now contain CAS numbers and other unique identifiers.
- The U.S. Department of Defense uses National Supply Numbers (NSN’s) (and closely related NIIN numbers) to uniquely and permanently identify items that it purchases.
- NSN’s are not very widespread on SDS’s, but are seen once in a while.
- EC Numbers (formerly known as EINECS or ELINCS numbers) are assigned to chemicals sold commercially in Europe, but this numbering system covers only ~100,000 chemicals.
UN/NA numbers are another identifying system used in transportation. However, there are only a few thousand UN/NA numbers assigned (out of 114 million+ known chemicals). UN/NA numbers are generally useful only for emergency personnel responding to transportation accidents involving the most commonly used chemicals in commerce.
- The only place one generally encounters these are on numbered DOT placards,
- Does OSHA determine what information is required under health hazard information or can we use our own data? OSHA has some very explicit requirements listed under Appendices A and B of the HCS 2012 standard.
- Note, however, per Section A.0.2, this does not require that one perform any testing of chemicals.
You may simply rely on the available scientifically valid data (if any). Under Appendix B of the now-obsolete HCS 1994 standard and earlier versions, there was only a terse set of general guidelines. Chemical manufacturers, importers, and employers evaluating chemicals were not required to follow any specific methods for determining hazards as long as they could show that they “adequately ascertained” the hazards of the chemicals.
Given the relatively low requirements, it has been said that this portion of the HCS 1994 “put the fox in charge of the henhouse.” This change in required hazard information reflects the shift from the HCS’s original “hazard determination” requirement to one of “hazard classification”. The difference in these terms is very significant.
See our SDS HyperGlossary entry on Hazard Classification for more information. Do I need to make a new SDS if I mix several other chemicals together (each of which already has an SDS)? Paragraph (d)(3) and Appendices A and B of the OSHA HazCom Standard address this question in considerable detail.
Per paragraph (d)(3)(i), if you have a non-interacting mixture of components then you can simply make a new SDS based on the sheets you already have. This principle has been part of the HCS since its inception; for example, see this OSHA Interpretation titled ” MSDS requirements for products that are composed of a mixture of non-interacting chemicals “. If you have a complex mixture such as crude oil where the exact chemical composition may vary from batch to batch you can get away with one generic SDS to cover a range of compositions per 29 CFR 1910.1200 paragraph (g)(4), In fact, petroleum mixtures are so complex, they merited their own separate appendix to CPL 02-02-079, the OSHA document which defines the inspection procedures for the HazCom Standard. These older OSHA interpretation letters may also still be relevant:
” Generic MSDSs to cover different products that contain the same chemicals in different proportions ” ” One MSDS may apply to multiple complex mixtures having similar hazards. ”
In most cases, the components will interact or chemically react to create another product. If so, a new SDS must be constructed which means you will need to go through the rigorous process of hazard classification which is described in Appendix A of HCS 2012, The word “mixture” appears 331 times in Appendix A. Recall that no testing is required, but if no test data is available, then one must rely on a series of “bridging principles” for each hazard class. If those are not available, then a series of cut-off values and concentration limits are applied. And each type of hazard class has its own set of rules. Unless you’re a toxicologist, your head will probably explode trying to understand it all. For example, try reading just section A.0.5 of Appendix A which discusses bridging principles in general. Therefore, in these cases, you would most likely require professional assistance, Also see Who can write an SDS? (below) for some further insights and guidance. If the workplace where the mixture is created qualifies as a laboratory under the OSHA Laboratory Standard and the mixture is used solely within the laboratory itself, then no SDS is required per 29 CFR 1910.1450(h)(1)(i), But if that material is shipped to other locations (even other laboratories), one is required as discussed in the next question,
The mind-blowing requirements for mixtures under HCS 2012 may seem like regulatory overkill, but they really are not. When you mix substances that undergo chemical reactions, the resulting mixture may have completely different properties, risks, and hazards.
- For example, mixing aqueous ammonia and iodine together produces nitrogen triiodide, a powerful contact explosive, a hazard that would not be indicated by the SDS of either starting material.
- Do I have to write an SDS for new chemicals that I create in the laboratory? Generally, no.
- But if you plan on distributing these chemicals to others outside of your laboratory (for example, sending samples to other researchers), then you meet OSHA’s definition of a chemical manufacturer and must create an SDS for the materials.
This is assuming the new chemical meets OSHA’s definition of hazardous, which is a fairly good assumption for most chemicals. While this sounds daunting – creating an SDS for a few grams of material that nobody has ever made before and has myriad unknown properties, most of the information on your SDS will simply read “Not known” or something similar.
- See the question Who can write an SDS? for authoring tips.
- This applies for any amount of material you may be wishing to send elsewhere.
- The HazCom Standard is based on whether on not a material is hazardous, not the risk associated with a given amount of hazardous material.
- For an official OSHA interpretation on this see ” Material safety data sheet requirements for experimental chemical mixtures that are shipped off-site ” dated February 5, 2004.
Can the identity of a chemical be withheld on an SDS as a trade secret? Yes, but the criteria are very demanding and there are certain responsibilities that come with such a claim. See our SDS HyperGlossary entry on trade secret for more information. Who can write an SDS? In theory, anyone can write an SDS as long as they are capable of filling out the OSHA -required elements outlined in Appendix D of the Hazard Communication Standard,
- Whether you have the expertise it takes to produce an accurate and complete sheet is another matter.
- Note : Paragraph A.4.2.2 of Annex 4 of the model regulations for the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), on which the OSHA HazCom Standard is based, states The safety data sheet shall be prepared by a competent person who shall take into account the specific needs of the user audience, as far as it is known.
Persons placing substances and mixtures on the market shall ensure that refresher courses and training on the preparation of SDS be regularly attended by the competent persons. However, the term “competent person” is not actually defined, and OSHA did not incorporate this requirement into the language of HCS 2012,
- The European Union addressed this issue in EU regulation 453/2010 which amended the REACH regulation to cover this in paragraph 0.2.3 which states Suppliers of substances and mixtures shall ensure that such competent persons have received appropriate training, including refresher training.
- Prior to implementation of the 2012 version of the HCS, one only needed to perform a hazard determination, a task that was much easier than the hazard classification that is now required.
HCS 2012 also introduced some important new elements such as signal words (either Danger or Warning), pictograms, precautionary statements and hazard statements that had not previously been required. While these new elements are not all that difficult to figure out, the hazard classification process can be quite daunting to many.
Unless your SDS is for something common for which you can use other SDS’s as a starting point, or for a laboratory sample for which most of the information may be “not applicable (N/A)” or “none”, then you may want to consider hiring a professional, But if you want to try, OSHA has a guide titled Hazard Classification Guidance for Manufacturers, Importers, and Employers that will greatly assist you in the hazard classification process.
They also have numerous technical information resources available that can assist SDS authors. Regardless, recognize that you assume some significant legal responsibilities (see earlier in this section ) as the author of an SDS. So if you do not think you are capable of producing an SDS that can meet all the requirements, we suggest outsourcing the project,
Although this article was authored well before HCS 2012 was written, you can find some excellent tips on writing an effective (M)SDS at http://www.osha.gov/dsg/hazcom/hc2inf2.html, This 1997 study includes a finding that ” one expert panel review established that only 11% of the MSDSs were found to be accurate in all of the following four areas: health effects, first aid, personal protective equipment, and exposure limits,
Further, the health effects data on the MSDSs frequently are incomplete and the chronic data are often incorrect or less complete than the acute data”. Therefore, while you can easily make a new SDS for a common chemical (such as acetone) using another sheet as a template, be sure to triple check the information and document your effort! One easy way to look up or double check technical information required on SDS’s is OSHA’s Occupational Chemical Database,
- Here you’ll find concise data on a large number of chemical substances that may be encountered in industrial hygiene investigations.
- It’s not all the data you’ll need, but it gives you a good start.
- The RTECS database is another good resource and contains toxicology information on over 168,000 compounds! Those writing sheets for the European market should check out the link to the European Chemical Bureau in our FAQ question on European SDS requirements,
One truly fantastic resource now coming up to speed is the NIH’s PubChem open chemistry database which has Laboratory Chemical Safety Summaries (LCSS) on over 152,000 compounds as of February 2022. The key point of this resource is that every piece of data is referenced back to the original source materials, meaning that you are not relying on secondhand information and can document where you came up with the physical or toxicological data on the sheet that you are authoring.
- Moreover, the LCSS also includes multiple sources for most data, so the user can look at the variability and reliability of the data when deciding which value to enter on their SDS.
- We expect LCSS’s to revolutionize the way that chemical safety data is communicated and, in particular, to greatly assist the hazard classification process.
If you are interested in taking a professional SDS authoring course, AIHA offers an SDS and Label Authoring Registry self-study course ($499 for members, $699 for non-members) as well as a Safety Data Sheet Registered Professional (SDSRP™) credential.
Where does one submit SDS’s for official approval? How do I know if an SDS is accurate? There is no guarantee an SDS is accurate. As discussed in the previous two FAQ questions on this page, anyone can write an SDS and there is no agency that reviews or approves them, While the United States legal requirements for the content of an SDS as well as the procedures for performing the hazard classification for a chemical are provided in the Appendices of 29 CFR 1910.1200, the OSHA Hazard Communication Standard, the end user of the SDS generally has to take it on faith that the author(s) of the sheet followed the procedure correctly and did full due diligence in doing so.
This is not always the case, and inaccuracies on SDS’s are fairly common. For general laboratory and commodity industrial chemicals, many in the chemical safety community have found that SDS’s authored by major US manufacturers and laboratory supply companies such as Millipore Sigma (Aldrich), Thermo Fisher Scientific, and VWR/Advantor tend to be above average in reliability.
Likewise, for consumer products, major national brand names also tend to be more reliable. Generally, major companies with diverse product lines are more likely to have rigorous systems in place for authoring SDS’s, but this is just a rule of thumb. However, there is no guarantee that just because a company is big or well-known that the SDS is accurate, and smaller companies are certainly capable of producing an accurate sheet if they devote the necessary resources.
Folks who have concerns about a sheet’s accuracy often compare the SDS’s for the same material from different manufacturers, If one finds inconsistencies between different sheets for the same chemical, particularly regarding measures of toxicity, flammability, personal protective equipment, or other areas of concern, it is a good idea to look up original sources of scientific data for those items.
- While few sheets list their source data, several excellent data resources are discussed in the FAQ question ” Who can write an SDS? above.
- A 2022 article titled When Safety Data Sheets are a Safety Hazard which appeared in Org.
- Process Res.
- Dev.2022 provides examples of erroneous statements found in SDS’s and analyzes their origins, however this article is paywalled.
While we are not attorneys and this is not legal advice, if you have doubts about the accuracy of an SDS you were provided with, it is probably a good idea to document your research as well as what actions you did or did not take based on your findings.
- In the European Union, the responsibility for the accuracy of an SDS falls not just on the original author, but on others in the downstream flow,
- Specifically: In all cases, suppliers of a substance or a mixture which requires a safety data sheet have the responsibility for its contents, even though they may not have prepared the safety data sheet themselves.
In such cases, the information provided by their suppliers is clearly a useful and relevant source of information for them to use when compiling their own safety data sheets. However, they will remain responsible for the accuracy of the information on the safety data sheets they provide (this also applies to SDSs distributed in languages other than the original language of compilation).
It should be noted that the supplier always needs to add their contact details in Section 1.3 of the SDS, even when they use the SDS from their supplier without changing any content (see section 3.1 of this guidance document for more details). See the ECHA document Guidance on the compilation of safety data sheets,
See also: The SDS FAQ question Are we protected from liability if someone is injured because an SDS supplied to us is wrong but we had no way of knowing about the error?, Are SDS’s copyrighted/copyrightable? Disclaimer : we are not intellectual property attorneys etc., so this is our non-expert response to this question.
- Manufacturers, distributors etc.
- Are required to give SDS’s to downstream users at no charge so there is really no point in formally copyrighting them.
- In fact, given that HCS 2012 requires SDS’s to follow a standard format and language, it is unlikely in most cases that one would be able to have an enforceable copyright.
One could reasonably argue that most SDS’s are derivative of previous ones or that they simply constitute a list of facts, neither of which merits an enforceable copyright. On the other hand, if one “gussies up” a sheet with a particular graphic design, organization, and other elements that represent original creative work, then the sheet (in that form) could theoretically be copyrighted.
- Of course, nothing prevents someone from extracting the basic scientific facts and printing them in a different form.
- Over the years we have seen at least a few companies produce SDS’s with copyright notices.
- Whether that is an enforceable copyright is unclear.
- We are unaware of any successful litigation involving violation of an SDS copyright.
That said, we are aware of a several instances in which someone had posted SDS’s to a web site and was sent a takedown notice under the Digital Millennium Copyright Act, Those are tough to beat. If the author of the sheet issues one of those and you want to contest it, you will probably need a lawyer or may have to relocate your web/business presence to a country outside US legal jurisdiction.
See SIRI’s site for another opinion. There are lots of other great web sites on copyright law; a quick search at Yahoo, Google, Teoma etc. should offer hundreds of possibilities. The complexity of this goes way beyond the copyright aspect. Imagine a manufacturer being sued by a client who needed an SDS that was required by law.but who couldn’t get it because of a confusing copyright issue.and then there being an accident involving that material.and someone suffering great pain, injury or death.
Could be quite ugly. On the other hand, consider the viewpoint of a manufacturer who issues regular updates to their SDS’s and does not want multiple outdated versions of them floating around in cyberspace; what happens if there is an emergency and someone grabs an old version with incorrect or outdated information? Either way, these scenarios illustrate that free and unfettered access to safety information is the best way to go.
- All manufacturers should post their SDS’s on their web site and ensure that every sheet includes a permanent web link (no more broken URL’s!) where the user can go to see if they have the latest version.
- Is there an XML standard for SDS’s? The Defense Environmental Network & Information eXchange (DENIX) has been working on draft DTD’s (data type definitions) for MSDS’s and they welcome your insight and input on the proposed standard.
However, we have not noted any changes in this site (and therefore progress on the DTD) since 2010, and the current information available is quite sparse, as you can see. More recently, eSDSCom has been working on an industry consensus format they call SDScomXML,
They have released an operational version that you can download, but we haven’t taken a look at it ourselves. They are apparently planning to publish an updated version in spring of 2017, If anyone has further information or experience with this effort, we’d love to hear from you. XML stands for e X tensible M arkup L anguage, an configurable extension of HTML, the language used to author web pages.
XML permits industries to come up with a set of tags that define information content within a document, not just document structure. For example, in an SDS, one could surround the address information with, tags or the CAS number with, tags. These tags would be invisible to the reader, but any computer reading the document could automatically extract (or insert) this information.
That allows the data to be imported/exported to databases, cell phones, internet appliances etc. with no human intervention, and provides superior data access. We strongly support and encourage the development of an SDS XML standard. For more about XML, see World Wide Web Consortium (WC3)’s XML recommendations,
Notice : This page is copyright 1998-2023 by ILPI and was last updated Wednesday, February 16, 2022, Unauthorized duplication or posting on other web sites is expressly prohibited. Disclaimer : The information contained herein is believed to be true and accurate, however ILPI makes no guarantees concerning the veracity of any statement.
What should be on a safety data sheet?
The SDS includes information such as the properties of each chemical; the physical, health, and environmental health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical.
Is there a standard format for SDS?
SDSs come in different formats, however the American National Standards Institute (ANSI) format is highly recommended by OSHA. The sections below summarize how to read an SDS in the ANSI format. equipment, etc.) Describes handling procedures, storage containers and especial conditions (incompatibilities, etc.)
Who develops or prepares the safety data sheet?
Purpose – A Safety Data Sheet (formerly called Material Safety Data Sheet) is a detailed informational document prepared by the manufacturer or importer of a hazardous chemical. It describes the physical and chemical properties of the product. SDSs contain useful information such as toxicity, flash point, procedures for spills and leaks, storage guidelines, and exposure control.
See SDS Explained to learn how to read a Safety Data Sheet.
Is SDS free?
Use Guidelines – Chemical Safety’s SDS and GHS database is a free service available to organizations of all types. For-profit organizations are granted permission to access Chemical Safety’s SDS Search from Chemical Safety’s website. There are no restrictions on the number of searches performed.
Are SDS sheets free?
Suppliers are required to supply SDS files free of charge to their customers. SDS Manager simplifies this process by collecting all available Safety Data Sheets in one place.
What is SDS template?
What is a Safety Data Sheet? – A safety data sheet is a document that provides explicit information about the hazards, properties, and safe use of different chemicals. This document also serves as an occupational safety guide for handling hazardous chemicals in the workplace.
Can SDS be digital?
Managing SDS Online – These days, many organizations use several methods to access safety data sheets. They use systems such as online SDS management programs to access the sheets from anywhere at any time. Some systems even have mobile apps and other methods of accessing the sheets. This is true even when the main computer system or cloud is unavailable for any reason.
Who writes the MSDS?
MSDSs are prepared by the supplier or manufacturer of the material.
What is SDS cost?
SDS Pricing | Self-Directed Search Pricing For a single user, the SDS online experience includes test administration and a comprehensive, customized report for just, You may pay by credit card, through PayPal®, or with a Group ID and password (if these have been provided to you).
- Then click “Take the SDS.” Enter the required demographic information and click “Continue.” Once you complete the test, a customized report will be generated.
- You can view your comprehensive interactive report and save or print your summary report immediately.
- Group Accounts (Bronze) Those who administer the SDS frequently or need to purchase more than one administration should consider a group account, which offers discounted pricing.
With an SDS group account, you can also designate an email address where your clients’ reports can be sent. Partnerships (Silver) Similar to a group account, partnerships allow you to purchase a set number of SDS administrations. An SDS Partnership is perfect for organizations who plan to administer the SDS 300 or more times.
- You can designate an email address where your clients’ reports can be sent.
- You can also tailor group access via a customized partnership web page.
- The page can include your logo and branding and any instructions you wish to provide.
- Institutional (Gold) Rather than pay a cost per use, with institutional pricing one flat fee allows you to administer the SDS an unlimited number of times.
This allows school districts, colleges, universities and enterprise organizations of all types to utilize this tool across any number of departments or programs. In addition to all of the benefits group accounts and partnerships receive, institutional accounts are also able to monitor their clients’ usage and results; and receive a data file of your clients’ assessment results for further analysis.
Setting up an account for multiple administrations is quick and easy. Please fill out the form above for more information, including group, partnership, or institutional pricing, or to set up an SDS demonstration for your institution. We offer purchasing by credit card, check, wire transfer, or institutional purchase order if ordering within the U.S.
or Canada. For more information about SDS group accounts, partnership and institutional pricing please contact Matt Parks at, or call 1.813.482.8141. : SDS Pricing | Self-Directed Search Pricing
Are SDS used internationally?
From Wikipedia, the free encyclopedia “MSDS” redirects here. For the video game, see MapleStory DS, An example SDS, including guidance for handling a hazardous substance and information on its composition and properties. A safety data sheet ( SDS ), material safety data sheet ( MSDS ), or product safety data sheet ( PSDS ) is a document that lists information relating to occupational safety and health for the use of various substances and products,
- SDSs are a widely used system for cataloguing information on chemicals, chemical compounds, and chemical mixtures,
- SDS information may include instructions for the safe use and potential hazards associated with a particular material or product, along with spill-handling procedures.
- The older MSDS formats could vary from source to source within a country depending on national requirements; however, the newer SDS format is internationally standardized.
An SDS for a substance is not primarily intended for use by the general consumer, focusing instead on the hazards of working with the material in an occupational setting. There is also a duty to properly label substances on the basis of physico-chemical, health, or environmental risk.
How much does SDS software cost?
|Number of Chemicals||Price|
|Up to 500||$359.88|
|Up to 1000||$599.88|
|Up to 2500||$1199.88|
What are SDS sheets called now?
From MSDS to SDS – MSDS (Material Safety Data Sheet) is now called an SDS (Safety Data Sheet). The purpose of both MSDS and SDS documents remains unchanged and is to list the information pertaining to the occupational health and safety for the various uses of the substances and products.
Does water require an SDS sheet?
That’s a valid concern. Water does not require an SDS because it does not meet the OSHA definition of hazardous, but that hasn’t stopped companies from issuing them for non-hazardous materials. However, remember that even seemingly “harmless” substances such as table salt (sodium chloride, NaCl) may be dangerously incompatible with other substances or when their concentration or amount is higher than we normally encounter.
- See this 1993 OSHA interpretation letter for more information.
- For example, many think that oxygen poses no unusual risks because we breathe it all the time (it is 21% of the Earth’s atmosphere ).
- But at 100% concentration, it is an extreme fire hazard and can even ignite some organic materials spontaneously ! Common table sugar wouldn’t seem dangerous.
But a 2008 sugar dust explosion at a Georgia sugar refinery killed eleven workers and injured 44 others, 20 of whom required treatment at burn centers. So maybe an SDS with a warning about dust explosions isn’t so silly after all. For a real-life assessment of 88 commonly used chemicals, take a look at Prudent Practices in the Laboratory: Handling and Disposal of Chemicals which is free to read on-line.
- Also check out ” How should we handle SDS requests for materials that do not require an SDS? ” elsewhere in this FAQ.
- Even if some of the information in SDS’s is in there to satisfy lawyers, it is in your best interest to assume a worst case scenario.
- A good analogy is professionals who work with blood products.
These workers must assume “universal precautions”, assuming that every blood sample they work with could transmit HIV or hepatitis even though few actually do. The payoff is in a greatly reduced risk of accident due to complacency. Respect the chemicals you are working with and know their hazards (and how you would respond to a spill, leak or other accident) before using them! For a humorous look at chemophobia (fear of chemicals) and SDS’s take a look at the very cleverly done web site DHMO.org (yes, the whole site is a joke.DHMO is water).
How many sheets does SDS have?
The Sixteen (16) Sections of the Safety Data Sheet (SDS) The Global Harmonization System (GHS) is a product of the United Nations that embodies an international approach to hazard communication using an agreed upon criteria for classifying hazardous chemicals and a standardized method to communicate the hazards through use of container labels and Safety Data Sheets (SDS).
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Appendix D to 29 CFR 1910.1200 indicates the required (and suggested) information to include in the SDS and the format. Sections 1-11 and 16 are required, sections 12-15 may be included but are not required.
Section 1—Identification: Product identifier, manufacturer or distributor name, address, phone number, emergency phone number, recommended use, and restrictions on use. Section 2—Hazard(s) identification: All hazards regarding the chemical and required label elements. Section 3—Composition/Information on ingredients: Information on chemical ingredients and trade secret claims. Section 4—First-aid measures: Required first aid treatment for exposure to a chemical and the symptoms (immediate or delayed) of exposure. Section 5—Fire-fighting measures: The techniques and equipment recommended for extinguishing a fire involving the chemical and hazards that may be created during combustion. Section 6—Accidental release measures: Steps to take in the event of a spill or release involving the chemical. Includes: emergency procedures, protective equipment and proper methods of containment and cleanup. Section 7—Handling and storage: Precautions for safe handling and storage, including incompatibilities. Section 8—Exposure controls/Personal protection: OSHA’s permissible exposure limits (PELs), threshold limit values (TLVs), appropriate engineering controls, and personal protective equipment (PPE). Section 9—Physical and chemical properties: The chemical’s characteristics. Section 10—Stability and reactivity: Chemical stability and possible hazardous reactions. Section 11—Toxicological information: Routes of exposure (inhalation, ingestion, or absorption contact), symptoms, acute and chronic effects, and numerical measures of toxicity. Section 12—Ecological information: How the chemical might affect the environment and the duration of the effect. Section 13—Disposal considerations— describes safe handling of wastes and methods of disposal, including the disposal of any contaminated packaging. Section 14—Transportation information— includes packing, marking, and labeling requirements for hazardous chemical shipments. Section 15—Regulatory information— indicates regulations that apply to chemical. Section 16—Other information— includes date of preparation or last revision.
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The Sixteen (16) Sections of the Safety Data Sheet (SDS)
Are electronic copies of SDS sufficient?
ERROR: Trying to get property ‘site’ of non-object Hello-I’m Jill, Chief Safety Officer with HSI Learning Systems. Employers often ask whether or not Safety Data Sheets or SDS’s can be housed on an electronic or online system for employee use. The answer is yes if they are accessible to employees.
What does accessible mean? It means no passwords-no logins can exist that would be a barrier to information. For those of us who remember a time when employers stored SDS’s or MSDS’s as they were called years ago in a binder and that binder often hung on a wall in a work area, it was accessible. Now, imagine if that binder was stored in a box on the wall with a lock on the box and employees didn’t have the key, those MSDS’s would not have been accessible.
Same is true of electronic or online access, there cannot be barrier to this critical information which is most often needed in times of crisis where someone needs to access the information immediately. I hoped this helped clarify one aspect of Hazard Communication Compliance.
Are physical copies of SDS required?
Chemicals With Physical Hazards –
- acute toxicity,
- skin corrosion or irritation,
- severe eye damage or eye irritation,
- respiratory or skin sensitization,
- germ cell mutagenicity,
- reproductive toxicity,
- specific target organ toxicity, or
- aspiration hazard.
Chemicals pose a physical hazard in the workplace if they are:
- organic peroxide,
- corrosive to metal,
- gas under pressure, or
- in contact with water and emit combustible gas.
If you have any chemicals that pose health or physical hazards at your workplace, OSHA regulations state that you must create an electronic or hard copy file of all SDS documents.
Can you get SDS online?
How do you obtain an SDS? – The University of Iowa retains a contract with Chemwatch, an online database that maintains SDS for the University community. Each PI/area manager is expected to keep an up-to-date manufacturer-specific chemical inventory in EHS Assist.
- So long as the PI/area manager does this, corresponding SDS will be available in Chemwatch.
- If the chemical inventory in EHS Assist is complete and up-to-date, the PI/area manager does not need to acquire SDSs themselves.
- If you do not have access to Chemwatch due to an incomplete inventory, the PI/area manager is still responsible for having manufacturer-specific SDS available for lab workers.
To obtain SDS, get them from the manufacturer.
They may be sent with the chemical order (paper copy or e-mail attachment). Otherwise, go to the manufacturer’s website and download it or request a copy.
If you cannot obtain a vendor-specific SDS, replace the chemical with one for which an SDS is available. If that is not feasible, contact John Silka at 335-8031.
Are SDS legally required?
That really depends on how SDS’s are handled at your organization. If your employer uses a software program or Internet subscription service for SDS’s then maybe not (check with your supervisor, the answer depends on what state and federal agencies have jurisdiction, see also the section on paperless compliance below.). If the copies you received are exact duplicates (and not updated ones) of sheets that you already have in your ” readily accessible ” SDS collection, then there is no requirement to keep the extra copies on hand. However, be sure to carefully check the revision dates on your sheets to make sure there haven’t been any changes/updates that you might otherwise overlook! And should you receive an updated sheet, then be sure to read the question, ” Can I throw away old or outdated MSDS’s? ” for information on what to do with the old sheet. When you get the same chemical with the same formulation from several different manufacturers the situation is a little more complex. See the next question below for more information.
Yes. SDS’s must be specific to the manufacturer and contain the contact information for the “responsible party”, Per paragraph G.1.l of Directive Number CPL 02-02-079, SDS’s must be specific to the product and manufacturer. In theory, you could get away with one sheet for the chemical if certain conditions are met. See the OSHA Interpretation titled Hazard Communication Standard and Material Safety Data Sheets, The key points are:
- The identity on the label must be able to be cross-referenced to the SDS
- All employees must be trained that you are using one SDS as representative of all vendors (so there isn’t confusion during an emergency).
- The SDS must be complete and accurate.
- The manufacturer listed on the SDS is willing to act as the responsible party in the event of an emergency. There is no legal requirement for them to assist you with another company’s product,
Later in the same document, OSHA writes The specific chemical’s MSDS itself, not just “MSDS information” must be available to workers. If the MSDSs utilized in your electronic system are specific to each product and contain the same chemical identity as used on the required label of the chemical, so as to allow cross referencing between the two, then this aspect of your system would meet the intent of the standard. If the MSDS provided is not product specific, the intent of the standard would not be met. Obviously, there is no harm in keeping an SDS from each manufacturer, and it probably takes less effort to do so than meeting all of the above conditions. Further, it is presunably in your best legal interest to maintain documentation from each supplier/source, particularly for your employee exposure records or in the event one had to, for example, sue the manufacturer(s) of the material at some future date. Consider that different manufacturers may come to different conclusions regarding the various data they report. Having that specific data in hand may be of particular importance when one manufacture, for example, overlooked a finding of carcinogenicity or reported a different freezing point etc. Also see the previous question in this FAQ, Do I have to keep every SDS that I receive?
Under the OSHA HazCom standard (HCS), manufacturing employers were not legally required to obtain, maintain, and make available upon request copies of MSDS’s until May 26, 1986; see this official OSHA interpretation ” MSDSs for chemicals purchased prior to 1985 “. If you have not received a new shipment of the material since then, you are in the clear. Of course, a reasonable question is “what are you doing with a 30+ year old chemical?” Use it up, recycle it or properly dispose of it! If the chemical is so vital that you can’t dispose of it and the solutions in the next question don’t help, consider having an SDS supplier author one for you. For chemicals that were delivered after the HCS took effect but are no longer produced, you can try the distributor you purchased the material from or the manufacturer directly per the principle of “downstream flow”, You may run into some issues if the material is no longer manufactured or has been reformulated, so some effort may be required. See the next question for one possible resource, the Wayback Machine, and more. The big issue is what to do when the manufacturer has gone out of business or merged. That situation is discussed in the next question.
OSHA has confirmed that manufacturers who are no longer in business or who have discontinued a product line do not have to provide SDS’s. See ” Requirements for manufacturers, who are no longer in business or have discontinued a product line, to provide MSDSs and product information ” (May 27, 2004). Normally, a manufacturer going out of business should not affect you because you already have an (M)SDS on hand. Per Paragraph G.4.f of Directive Number CPL 02-02-079 (Inspection Procedures for the Hazard Communication Standard) ” If the manufacturer has gone out of business, the employer’s responsibility is to maintain the SDS (or MSDS) for that product and not to create a new SDS. ” However, most people asking this question didn’t get around to getting one in the first place. Avoid falling into that category by establishing a formal inventory/review procedure for hazardous materials in your workplace. In laboratories, this would be incorporated into the Chemical Hygiene Plan, Either way, if you regularly review your inventory so as to use up or dispose of chemicals older than say, three years, you are likely to never encounter this problem. Many of our visitors use these weather-resistant SDS storage boxes like this one. We have 3 different sizes available at www.SafetyEmporium.com, As far as the impact this has on an workplace where these obsolete chemicals are still in use and no (M)SDS was ever obtained, we have been hard-pressed to find an actual OSHA interpretation. Our best guess is that they would require you to make a documented “good faith” effort to locate a sheet, starting with the manufacturer (see OSHA Field Operations Manual CPL CPL02-00-159 for more about good faith). If you are not using an SDS software package or SDS supplier who can assist you, start by figuring out what happened to the company. While many companies go bankrupt, their assets and product lines are usually acquired by other manufacturers. Try a web search on the company name. The U.S. Securities and Exchange Commission keeps records of publicly-traded companies, mergers and acquisitions, so you might try there as well. One resource that might work is the Internet Archive’s Wayback Machine which preserves snapshots of web sites over the years. If you know or can determine the web site of the company, enter that in the Wayback Machine and you may be to browse your way, for example, to the MSDS’s that Solutia had in 2004 (they were bought by Eastman Chemical in 2012). If all else fails, see if you can find an SDS for an identical formulation from another manufacturer (see ” Do I have to keep every SDS that I receive? ” above and OSHA comments on generic MSDS’s in the previous section ). As long as you’ve made documented efforts such as these and you don’t have any willful violations of any type you are probably (this is our best guess) looking at a “de minimus” violation, i.e. one where OSHA might note it during an inspection but not assess a penalty. If you are looking for the SDS because you have the material in your current inventory, one might be tempted to simply use it up to eliminate the need to have the SDS. However, you still need to document your company’s use of that material under 29 CFR 1910.1020, Access to Employee Exposure and Medical Records, and the SDS is normally the easiest way to do that. And while you might be tempted to simply dispose of the material as hazardous waste, it’s most likely that the disposal firm would require you to produce an SDS before accepting the waste.
Yes, they are required to supply an SDS. But under paragraphs (g)(6) and (g)(7) of the HazCom Standard they are only required to give you one copy:
- With the first shipment of a particular chemical,
- With the first shipment after the the SDS has been updated,
- Upon request, if you are a distributor or employer.
The second and third items only occur if you purchase the chemical after the sheet was changed. If you bought the chemical and the sheet was later updated, few firms would even attempt to let you know. But the next time you buy that chemical they have to send you the updated sheet. Get a grip on your laboratory equipment with clamps and supports from Safety Emporium. For over-the-counter retail or wholesale sales to employers (but not consumers ), paragraph (g)(7) of the HazCom Standard requires the seller to provide the SDS upon request and to post a sign that an SDS is available. If a retailer does not have commercial accounts and does not use the material, then they are ony required to provide an employer with the contact information for the distributor, manufacturer or importer who can supply the sheet. Some chemical suppliers ship SDS’s with every shipment, others hold to the minimum standard. The latter practice can be a real pain at a large organization where it may be the first time you ordered that chemical, but it’s not the first time your employer (i.e. the purchaser) did. Fortunately, most manufacturers are happy to provide additional copies of an SDS if you simply contact their customer service department and ask. In fact, many of them have realized the benefit of making all their SDS’s freely available on the Internet, To help ensure that your suppliers comply with OSHA requirements, it can’t hurt to add the following sort of statement to your purchase orders: As required under the OSHA Hazard Communication Standard 29 CFR 1910.1200, a safety data sheet (SDS) must precede or accompany the initial shipment of any hazardous material defined as such under the Act. For items previously ordered, an SDS must also be supplied if the SDS has changed since the previous shipment. Another good idea for over-the-counter purchases is to require your employees to provide not only receipts for their purchases, but SDS’s.
As required by OSHA, SDS are dated when they are issued AND when:
- Any significant change has been made to the chemical compound or
- Research has revealed significant new information regarding the hazards of a chemical, or ways to protect against the hazard
According to OSHA 1910.1200 (f)(11), a new SDS must be issued within three months (and the labels updated within six months) if either of these conditions are met. As described elsewhere in this FAQ, the old SDS should be retained to potentially limit future liability. Recognize that this update requirement does not require the manufacturer to send a new SDS to you if you purchased a chemical prior to the SDS update. In other words, your SDS’s will go out of date from time to time, It is a good idea to review your collection on a set basis and to update your sheets. What time frame to use is up to you. The NTP updates its annual report on carcinogens each year, but perhaps longer is more appropriate depending on the nature of the materials and your business. You should consider setting a corporate policy on the matter. Alternatively, you can subscribe to an SDS software vendor or SDS supplier so you always have up-to-date sheets. Those of you in Great Britain (and presumably the rest of the European Union) will be pleased to hear that CHIP requires the supplier to notify anyone who received the material in the previous 12 months if there is a change in the SDS. See the European entry in the International section of this FAQ for more information. In some countries, SDS’s have expiration dates. See the International Section of this FAQ for Canadian and European regulations.
The Hazard Communication Standard ( HCS 2012 ) explicitly permits these compliance methods at paragraph (g)(8) : “.Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.” OSHA permits “paperless compliance” methods because the HazCom standard, like many OSHA standards, is performance-based, meaning that OSHA does not care how you comply so long as you comply. The employer must meet all of the following requirements, however:
- SDSs must be readily accessible with no barriers to employee access. This means reliable devices accessible at all times without the employee needing to ask anyone for permission.
- Workers must be trained in the use of these devices, including specific software.
- There must be an adequate back-up system and written plan for rapid access to hazard information in the event of an emergency including power-outages, equipment failure, on-line access delays, etc.
- The system of electronic access is part of the overall hazard communication program,
- Employees and emergency response personnel must be able to immediately obtain hard copies of the SDSs, if needed or desired.
Failure to provide ready access or to have that emergency back-up system in place would be considered a severe violation during an OSHA inspection, meaning that it is potentially subject to maximum fines exceeding $12,000, For more on this (and from a manufacturer’s perspective as well) the official OSHA interpretation titled ” 12/30/1997 – Manufacturer and employer responsibilities when providing SDSs electronically “.
The most popular types of electronic format these days are internet-based suppliers (which usually operate on a subscription basis), and “in-house” solutions where corporations scan their SDS into a database rather than use a paper filing system. Other versions that are falling by the wayside in the Internet era are CD-ROM subscriptions (renewable on a quarterly or annual basis) and fax-on-demand services (that will fax you a copy as soon as you request one).
Again, paperless compliance works only if the employees have ” ready access “. If your database is accessible to the required employees on your corporate intranet, you’ll probably be OK. This assumes that you have a written contingency plan to access SDS information in the event of a power failure or other emergency.
- Whether written programs may be kept solely in an electronic format. (09/16/2008)
- Material Safety Data Sheets (01/30/1997).
The OSHA Hazard Communication Standard, 29 CFR 1910.1200, paragraph(g)(8) says: The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access, microfiche, and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.) What constitutes “barriers”? For example, if your corporation owns an SDS CD-ROM but it is kept in a locked filing cabinet in the branch office in darkest Peru, OSHA will not consider you to be in compliance. Quoting OSHA again: Employees should not have to ask for an SDS, as this could be perceived by employees as a barrier to access. For instance, if an employee must go through a supervisor to receive an (M)SDS, the employee may feel that this singles him or her out. This could very well dampen the employee’s resolve to seek out necessary hazard information.” There is no specific time limit used to determine whether an access barrier exists. For a more detailed discussion, consult OSHA Compliance Directive CPL 02-02-079, Appendix A, Paragraph G.7, The OSHA inspector will interview your employees to ensure that they have “ready access” to the SDS’s and have been trained on the chemical hazards in their workplace. Failure to provide ready access is considered a severe violation during an OSHA inspection, meaning that it is potentially subject to maximum fines exceeding $12,000,
Full compliance means that every employee that uses hazardous chemicals in the workplace (or who could be expected to be exposed in a “foreseeable” emergency) has ” ready access ” to an SDS. Effective August 1, 2016, maximum OSHA fines for “serious” violations will rise from $7,000 to $12,471 and will be indexed for inflation thereafter. In the context of The Hazard Communication Standard, serious violations involve hazard classification, written Hazard Communication programs, labeling, and no or inadequate training, Serious SDS violations include :
- Failure to have a required SDS
- Failure to provide an SDS at the time of shipment
- Failure to provide an SDS upon request
- Failure to make SDS’s readily accessible to employees
- Failure to provide an emergency backup system when using electronic access to SDS’s
- Failure to provide SDS’s at multi-employer work sites,
OSHA is also raising the maximum penalty for “willful” violations from $70,000 to $124,709 (also indexed for inflation). Willful violations are issues the employer should have been aware of (based on previous inspections or workplace communications) and deliberately chose not to abate. And in all cases, these various penalty amounts are per violation, meaning one workplace could have dozens of violations during a single inspection. As of 2016, most SDS violations have been substantially lower than the maximums given above. You might simply get a warning if you have only a few minor infractions. See this OSHA interpretation letter from 1995 for more information. The Hazard Communication Standard (which includes SDS’s) is the most frequently cited OSHA standard in general industry and is the second most-cited standard across all categories, Acccording to FY2015 OSHA statistics, there were 3,210 inspections that reported violations of 29 CFR 1910.1200, resulting in 5,804 citations and fines totalling $3,377,765. That’s an average fine of $581 per citation or $1,052 per inspection, although some of these citations carried no fine.352 of the citations were related to obtaining or developing SDS’s under paragraph g(1) and 505 citations were related to maintaining SDS’s and keeping them readily accessible under paragraph g(8) (but we don’t have a breakdown of penalties for these, sorry). Note: OSHA has a Severe Violator Enforcement Program which targets firms that have demonstrated indifference to their OSH Act obligations by willful, repeated, or failure-to-abate violations. Although SDS issues alone will not trigger SVEP criteria, they can certainly contribute to the Severe Violator designation.
It depends. The HazCom standard is a performance-based standard which means that OSHA does not concern itself with how you comply, just that you manage to do it. See this 1994 OSHA Interpretation for a specific answer to this question. While your method of managing your SDS collection is flexible, specific criteria you need to meet are:
- SDS’s must be maintained on site (including electronic access methods ).
- SDS’s must be readily accessible during each work shift to employees when they are in their work area(s).
See the ready access question (above) for more about “readily accessible” and what an OSHA inspector will look for in determining compliance.
This topic is covered explicitly in paragraph (e)(2) of 1910.1200 under “multiemployer workplaces”, so follow that link for detailed information on this topic. Each contractor or employer has a responsibility to make sure the hazards of their chemicals (and, therefore, SDS’s) are known to all workers on the site. See the OSHA interpretation, HCS training for employees contracted to jobs working under the supervision of another employer, for additional information. The HazCom standard is performance-based meaning that OSHA does not care how the employers share this information as long the employees have no barriers to accessing the information when they need it and the plan for sharing this information in writing. Failure to make SDS’s readily available to all workers at a multi-employer worksite would be considered a severe violation during an OSHA inspection, meaning that it is potentially subject to maximum fines exceeding $12,000, The simplest solution for the multi-employer workplace is to provide each other copies of the SDS’s or to add your SDS’s to their collection (as long as your employees have access). Of course, other training, labeling etc. may be required; SDS’s are only a part of the HazCom standard.
As mentioned above, the OSHA HazCom standard is a performance-based standard. That means OSHA is not concerned with how you organize your SDS files, only that you ” ensure that they are readily accessible during each work shift to employees when they are in their work area(s) “. This can be by hardcopy, computer, internet subscription, fax etc., as long as the employee is able to use your system to find any sheet when he/she needs it. See this OSHA interpretation for more info. For an electronic system using an SDS software program or on-line service, organization is not really an issue as employees can call up SDS’s using various criteria such as chemical name, CAS Number, or chemical formula, But for those of you who simply file paper copies, how to order your filing cabinet or 3-ring binder is a more difficult question. Again, OSHA doesn’t care how you choose to do it, but employees have to be able to find the information when they need it. For this reason, many people prefer to file their SDS’s alphabetically by name. The biggest drawback to this is that one person might call a particular chemical ” acetone ” and another might call it “2-propanone”. Both are synonyms for the same chemical compound. We therefore suggest that you train your employees to file by the name listed on the container label. If you are into overkill, for each chemical synonym listed on the SDS, make a new page with that name as the title and write a note on it such as “see the SDS for acetone”. Another popular method in chemical laboratories is to file SDS’ by molecular or chemical formula, The standard convention is to list carbon and hydrogen first, followed by the other chemical elements in alphabetical order. If there is no carbon in the compound, then simple alphabetical order is used. For example, potassium carbonate, K 2 CO 3, would be listed as CK 2 O 3 and magnesium sulfate, MgSO 4, would be listed as MgO 4 S. The drawbacks here are that not all materials have chemical formulas (such as cleaning agents), and this system is more difficult for non-chemists.
Every case is different and we really don’t feel comfortable (from a legal and moral standpoint) trying to address such a complex issue. Hopefully, the points raised in this document will give you an idea of the parameters involved. Take a look at the previous question for some specific insights. The one recommendation we will make is that you maintain your paper copies. Beyond that, we’ll also say that some organizations will find it very advantageous to utilize one of the ” paperless compliance ” services discussed in this document. But that’s where our specific recommendations end, sorry.
We have all kinds of signs and labels at Safety Emporium that can assist you with OSHA compliance. No. Per paragraph G.4.b Directive Number CPL 02-02-079, The employer must not require employees to perform an Internet search (e.g., Google®, Yahoo® ) to view/obtain the SDS, and this page would fall into that same category. This makes sense when you consider the following:
- OSHA requires that your employees have ” ready access ” to the SDS’s. Unless you had an electronic database or SDS supplier/subscription that was guaranteed to have the SDS you need, your employees would likely have to spend many minutes to find the SDS they need in an emergency situation. In fact, it’s likely they might be completely unsuccessful in their search.
- Even if it were permitted, as a paperless compliance technique, you would need to have a backup capability in the event of a power failure or unavailability of Internet service. And if you’re going to that trouble, you might as well more simply purchase appropriate software or subscribe to an Internet service, Or stick with paper copies.
- If your company deals with exotic materials that are not in the common free databases, you’d have to maintain local copies of those SDS anyway, so it would make more sense to maintain all of them using one method.
That said, you can use our SDS page (and search engines or various Internet collections) as a source to find the electronic and hard copies of SDS’s that you need for your collection or to see if more recent sheets are available.
No. OSHA’s Hazard Communication Standard, 1910.1200 contains the minimum required elements for an employee information and training program. While SDS’s are a necessary part of these requirements, merely making these available or distributing them to employees is insufficient. According to an OSHA Interpretation letter ” Training programs for the Control of Hazardous Energy (LOTO) and for the Hazard Communication standard are not satisfied solely by merely providing employees written documentation ” dated October 24, 2005:, “he training provisions of the HCS are not satisfied solely by giving employees the data sheets to read. An employer’s training program is to be a forum for explaining to employees, not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways (audio visual, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them.” Moreover, with the advent of the HCS 2012 adoption of the GHS system, you will need to train your employees on labeling, pictograms, and other key elements of the HCS.
Yes and no. Paragraph (g)(2) of 29 CFR 1910.1200 of the OSHA Hazard Communication Standard requires that authors of SDS’s shall ensure that it is in English (although the employer may maintain copies in other languages as well), The same is true of label requirements. At first glance, it appears you do not need to make special provisions. However, the Standard also requires that your employees are adequately trained in:
- The hazards of all chemicals they use.
SDS’s are part of the hazard communication process and training requirements; if your employees do not understand English and you do not provide training in a language they comprehend then you are not in compliance. See this 1988 OSHA interpretation titled ” The employer must provide the 1910.1200 verbal training in a language that is comprehensible”, On April 28, 2010, OSHA issued an OSHA Training Standards Policy Statement that affirms the training requirement be understood in the employee’s language: http://www.osha.gov/dep/standards-policy-statement-memo-04-28-10.html, This statement includes the following: In practical terms, this means that an employer must instruct its employees using both a language and vocabulary that the employees can understand. For example, if an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand. Similarly, if the employee’s vocabulary is limited, the training must account for that limitation. By the same token, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation. As a general matter, employers are expected to realize that if they customarily need to communicate work instructions or otherworkplace information to employees at a certain vocabulary level or in language other than English, they will also need to provide safety and health training to employees in the same manner. Of course, employers may also provide instruction in learning the English language to non-English speaking employees. Over time this may lessen the to provide OSH Act training in other languages. See the International section of this FAQ for information on finding non-English sheets.
Per https://www.osha.gov/dsg/hazcom/hazcom-faq.html, OSHA estimates the total costs to comply with the revised HCS 2012 over the previous version as follows: The revised Hazard Communications Standard’s (HCS) total cost, an estimated $201 million a year on an annualized basis for the entire United States, is the sum of four major cost elements. (1) OSHA estimates that the cost of classifying chemical hazards in accordance with the GHS criteria and revising safety data sheets and labels to meet new format and content requirements would be $22.5 million a year on an annualized basis. (2) OSHA estimates that training for employees to become familiar with new warning symbols and the revised safety data sheet format under GHS would cost $95.4 million a year on an annualized basis. (3) OSHA estimated annualized costs of $59 million a year for management to become familiar with the new GHS system and to engage in other management-related activities as may be necessary for industry’s adoption of GHS. (4) OSHA estimated annualized costs of $24.1 million for printing packaging and labels for hazardous chemicals in color. We suspect that point 2 grossly underestimates the cost of hazard classification as companies that used to write SDS’s themselves will either have to spend considerable time learning the process or outsource their SDS production, Nonetheless, there will be considerable cost savings based on standardization of data and formats. On an individual basis, MSDS Solutions has a simple calculator that uses 5 pieces of data to calculate your costs.
That’s a tough question that only an attorney should answer, especially with the U.S. jury system! Given that tobacco companies seem to escape liability for selling products that are known to be defective while others are put into bankruptcy when there is scant scientific evidence supporting the claims against them, we’d be fairly reluctant to hazard a guess. A 2022 article titled When Safety Data Sheets are a Safety Hazard which appeared in Org. Process Res. Dev.2022 provides examples of erroneous statements found in SDS’s and analyzes their origins, however this article is paywalled. However, OSHA directive CPL 02-02-079 – Inspection Procedures for the Hazard Communication Standard, says in part ( paragraph G.4.b ): “Employers assume no responsibility for the content and accuracy of the SDS provided to them by the manufacturer, importer or distributor, unless the employer changes the SDS.” In other words, you won’t receive an OSHA fine or citation in the circumstance OSHA describes, but that doesn’t mean you won’t get hit with a lawsuit. You’ll need to contact an attorney who specializes in product liability for a complete answer to your question. Note that if you do become aware of a hazard/precaution that is missing from an SDS, then you need to make your employees aware of the new hazard/precaution in writing. You should also make an effort to notify the manufacturer, See the OSHA interpretation, “Requirements of the HCS and the employer’s ability to rely on a manufacturer’s hazard determination ” for futher information. In contrast, sending an SDS to a downstream customer in the European Union incurs a responsibility for accuracy even if the supplier has not changed the sheet they received. See the FAQ question How do I know if an SDS is accurate?, See also : FAQ questions ” Where does one submit SDS’s for official approval? and Does OSHA determine what information is required under health hazard information or can we use our own data? elsewhere in this FAQ.
To meet our visitor’s needs, we have compiled this list of pertinent reference books that are terrific resources. You can also search Amazon.com on-line from that page. If you need SDS binders, wall-mounted centers, training posters, Hazard Communication labels and more, check out our on-line store, SafetyEmporium.com, Notice : This page is copyright 1998-2023 by ILPI and was last updated Monday, January 17, 2022, Unauthorized duplication or posting on other web sites is expressly prohibited. Disclaimer : The information contained herein is believed to be true and accurate, however ILPI makes no guarantees concerning the veracity of any statement. Use of any information on this page is at the reader’s own risk. ILPI strongly encourages the reader to consult the appropriate local, state and federal agencies concerning the matters discussed herein.