Material safety data sheets (MSDSs) are the cornerstone of compliance for a number of OSHA and EPA standards. Yet, as notorious as they are among safety professionals, some argue that MSDSs remain regrettably underutilized.
Maintaining MSDSs is one of five key employer obligations under OSHA's hazard communication standard (HCS) – along with having a written hazard program, keeping a chemical inventory, properly using labels and training employees. When managed via a good electronic system, MSDS information can be indexed and used to easily create OSHA/GHS/WHMIS compliant labels and exported to produce a comprehensive chemical inventory that's available both electronically and in print if necessary. Furthermore, the data needed to train employees and put together a workplace hazard program flows from the chemical and precautionary information found on the MSDS, making MSDSs one of the single most important pieces of a hazard communication program as they directly affect all five employer responsibilities under hazcom.
When used to their full capacity, MSDSs have the potential to drive compliance and innovation in a wide range of environmental, health and safety areas, including: regulatory reporting, label creation, employee training, chemical/ingredient banning and sustainability. But first, safety professionals should understand the recent important changes to safety data sheet requirements in the United States.
MSDS and GHS Basics
Earlier this year, OSHA revised its hazcom standard (29 CFR 1910.1200) to align with the United Nations' Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Each country that adopts GHS uses the "building block approach," which means it takes only those parts of GHS that it wants and then is solely responsible for its enforcement.
To help distinguish the revised standard from its predecessor, OSHA calls its GHS-aligned standard HazCom 2012. One of the big changes GHS adoption brings to the United States involves safety data sheets. To understand those changes, let's review some MSDS basics.
MSDSs are documents required by OSHA to precede or accompany shipments of hazardous chemicals. They convey critical information regarding the manufacturer, composition, health and physical hazards, safe handling, and storage and disposal of chemicals to downstream users and emergency responders.
In the United States, MSDSs have for a long time been created in varying lengths and formats. OSHA's MSDS requirements were performance-based, giving chemical manufacturers and distributors wide latitude as to the order and the way in which the information in the document was presented.
This approach, unfortunately, put undue responsibility on the most vulnerable members of the chemical lifecycle: the downstream users, forcing employees to navigate a mixed bag of document styles to find the information they needed. Even for chemicals that are essentially the same (yet from different manufacturers or suppliers), MSDSs can have egregious differences. HazCom 2012 puts an end to this approach.
Under HazCom 2012, safety data sheets must adhere to a GHS prescribed format. Modeled after the ANSI MSDS format, GHS-styled safety data sheets have 16 sections that follow a strict order and are called SDSs. (Regardless of what they're called, MSDSs and SDSs serve the same purpose. )
GHS-formatted SDS sections include:
Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-Aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision
OSHA published the final rule on HazCom 2012 in the Federal Register in March, and it went into effect May 25. That means the clock is ticking for U.S. employers and chemical manufacturers to come into compliance with the revised standard. The first deadline is Dec. 1, 2013 – the date by which employers must train their employees on how to read GHS-formatted safety data sheets and labels. (Labels also get a big makeover under GHS.)
The most important deadlines related to MSDSs are June 1, 2015, and June 1, 2016. The first date is the date by which manufacturers must reclassify their chemicals using GHS criteria and then produce and ship safety data sheets in the new format to end users. The second date is when employers must be fully compliant with HazCom 2012 – meaning HazCom programs are up-to-date, employees are trained on new hazards and GHS formatted labels and MSDSs are fully integrated into the workplace.
The deadline for training employees on reading new format precedes the manufacturer deadline for producing GHS-formatted safety data sheets because OSHA expects the new documents to enter workplaces well in advance of the manufacturer deadline. This expectation is well founded, as many employers already are seeing an influx of MSDSs in the new format.
More MSDS Uses
MSDSs are rich in information, yet manually mining that information and trying to put it into a useful form can be a time-consuming and cumbersome task. This is where sustainable, cloud-based technology is making a difference in the EHS field.
By indexing the information on a safety data sheet with a robust electronic MSDS management system, safety professionals can harness the data of hundreds, or even thousands, of safety data sheets with a few clicks of a button. Information can be viewed at the 30,000-foot level to see larger patterns, or safety managers can drill down to a particular chemical at the container level – even tracking containers across an organization.
This insight helps businesses know not only what chemicals they have, but where and in what quantities. Take that tracking capability and combine it with a database of regulatory lists and quantity thresholds and now your MSDSs can help simplify regulatory reporting. For example, many manufacturers and employers are required to submit Tier II forms detailing use of chemicals above certain quantities per the EPA's SARA Title III Regulation. A good system easily can generate an exportable Tier II report, saving time and reducing redundancies.
Additional local, state, federal and international regulations could trigger reporting obligations for chemicals, even at low ingredient levels, for the most dangerous chemicals. Software is available to help track these ingredients across products, providing an early warning when important thresholds are about to be crossed.
In fact, many EHS professionals have safeguards to keep certain chemicals from entering their facilities in the first place. Chemical banning and other approval workflows automatically loop safety professionals into the conversation about the substances entering the workplace, which helps safeguard established chemical precedents. And for those sustainability-minded businesses, such vigilance provides a leg up on identifying and substituting the most dangerous chemical hazards in the workplace.
The Future of Mobile MSDS Compliance
Finally, the world of MSDS management and compliance has taken another great leap forward in recent months. Mobile units like iPad devices, smartphones and other tablets continue to redefine the terms "workplace" and "office."
Today, QR codes used on container labels work in tandem with iPads and scanner apps to provide in-the-field and on-the-go container management. Safety professionals now can look up MSDSs, track and inventory chemicals and produce secondary container labels with much greater flexibility than ever before.
If you have a shelf full of MSDS binders, now is the time to put them to work. Good MSDS management can help you reduce risk, save time, save money and get on the road to sustainability.
Chuck Haling is vice president of sales at MSDSonline, a provider of cloud-based compliance solutions for MSDSs and other EHS information. To learn more, visit http://www.MSDSonline.com or call 1.888.362.2007.