MSDS vs. SDS: Are you ready for the switch?

Chemical safety changes due by 12/01/13.

On December 1, 2013—about one year from now—more than 5 million U.S. workplaces will be required to be trained and ready for the new labeling requirements brought on by the alignment with the GHS (Globally Harmonized System) created by the United Nations and adopted by OSHA as the new HazCom 2012 standard. One key aspect of HazCom 2012 is the replacement of MSDSs (Material Safety Data Sheets) with GHS-aligned SDSs (Safety Data Sheets). The changes are designed to simplify communication regarding hazardous materials and promote international consistency.

MSDS and SDS: What’s the difference?

An MSDS is a lengthy document that accompanies a hazardous chemical. It indicates all the dangers associated with the material, as well as instructions regarding handling, storage and disposal. MSDSs are a key aspect of the Right-to-Know provision of OSHA’s Hazard Communication Standard (HazCom). The HazCom standard is being updated because the earlier version allowed for several formats for an MSDS, including an OSHA version with eight sections and an ANSI version with 16 sections. OSHA’s HazCom 2012, aligned with GHS, requires the internationally adopted 16-section version. The “M” in MSDS is being dropped as well. So in short, the name is being simplified, and the format is being standardized for ease of training and notification of hazards.

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

Section 1:    Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

Section 2:    Hazard(s) identification includes all hazards regarding the chemical; required label elements.

Section 3:    Composition/information on ingredients includes information on chemical ingredients; trade secret claims.

Section 4:    First-aid measures includes important symptoms/effects, acute, delayed; required treatment.

Section 5:    Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.

Section 6:    Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.

Section 7:    Handling and storage lists precautions for safe handling and storage, including incompatibilities.

Section 8:    Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).

Section 9:    Physical and chemical properties lists the chemical’s characteristics.

Section 10:  Stability and reactivity lists chemical stability and possibility of hazardous reactions.

Section 11:  Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

Section 12:  Ecological information*

Section 13:  Disposal considerations*

Section 14:  Transport information*

Section 15:  Regulatory information*

Section 16:  Other information: Includes the date of preparation or last revision and any other pertinent information.

*Note: OSHA won’t enforce Sections 12 through 15 because they fall under the regulatory authority of other agencies.

Create a GHS transition plan

Replacing your MSDSs with SDSs should be part of an overall transition strategy. Assigning a point-person to oversee the effort is a great way to keep the effort organized and create accountability.

Begin by taking a full onsite inventory of chemicals. Hand-in-hand with the SDS change is the responsibility of relabeling all secondary containers with HazCom 2012-compliant labels and training your employees regarding the new SDS format and corresponding labeling. Use GHS if you plan to ship chemicals internationally; otherwise use HazCom 2012 labeling. For big international jobs, having a HazCom labeling kit will save you time and money.

How to acquire SDSs

First, have your procurement and loading dock personnel be on the lookout for SDSs as they arrive with new chemical shipments, because providing them to employers is first and foremost the responsibility of the importer, manufacturer and distributor. (Receipt of the new SDS represents the ideal opportunity to compare it against the earlier MSDS to check for updated hazard information to cover in training.)

Otherwise, there are different ways to approach acquiring SDSs for your hazardous materials and the approach you take will vary depending on the size of your inventory and the resources at your disposal. SDS software packages and service providers may take the headache and much of the work out of the job. If neither of these options is appropriate, you may request SDSs from the manufacturer/distributor of the chemicals or, if you have a qualified industrial hygienist or chemical specialist on staff, generate your own SDSs based on the 16-section structure shown above.  (For more detailed requirements, request our HCS/HazCom 2012 Labeling Best Practice Guide). HazCom mandates having SDSs in English; if you have employees for whom English is a second language, make sure you also offer SDSs in the language they understand best.


Deadlines for full implementation of GHS standard

Effective Completion Date

Requirement(s)

Who

December 1, 2013

Train employees on the new label elements and safety data sheet (SDS) format. Pay special attention to Section 2, Hazard Identification.

Employers

June 1 and December 1, 2015

Compliance with all modified provisions of this final rule must occur by June 1, except that the distributor has until December 1 to comply with the rule stating ship containers must bear a GHS label from the chemical manufacturer or importer.

Distributors have until December 1 to pass along manufacturer labels and SDSs in the older formats. However, beyond December 1, 2015, all SDSs and labels in the U.S. should adhere to HazCom 2012 provisions.

Chemical manufacturers, importers, distributors and employers

June 1, 2016

Full compliance necessary for employers. Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

Employers

Transition Period to the effective completion dates noted above

May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both.

Chemical manufacturers, importers, distributors, and employers

 

 


 

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