GHS TRAINING COUNTDOWN: OSHA's HazCom 2012 Safety Data Sheet
Dropping ‘Material’ from the Name is Only the Beginning
Last month, we outlined some of the major changes to container labeling brought on by OSHA’s GHS-aligned HazCom 2012 standard. GHS Training for both the new labeling requirements for GHS labels and the new standardized safety data sheet (SDS) must be completed for all employees by December 1, 2013, just four months from now.
No More ‘Material’
The most obvious difference is the name. These documents were formerly known as material safety data sheets (MSDSs) and “material” has now been dropped from the name. From now on if you refer to a material safety data sheet or an MSDS, you will be referring to a document that will no longer be compliant on June 1, 2016. (Note that MSDSs can be filed as records of the hazardous materials you have kept in your facility, but they should not be referred to when looking up current hazardous materials.)
One Standard to Rule Them All
The next obvious difference is that the document has been standardized to match ANSI’s Z400.1-2004 standard. Like the ANSI version, the new standard calls for 16 sections addressing various categories of interest regarding hazardous chemicals, listed in a uniform order that never varies between SDSs. An SDS generated in China will have the same structure as one created in Chile or one from Chicago.
The 16 sections are arranged in order of importance, so that anyone scanning the SDS can quickly find critical hazard information or measures to be taken to prevent or minimize the damage of an industrial incident such as a chemical leak.
Reverse that Order, Please
A third difference is that the SDS ranks the severity of hazards with 1 being highest and 5 being lowest—opposite of the metric used by National Fire Protection Association (NFPA) in its 704 standard and commonly used on RTK labels. (In NFPA 704, 4 is the highest level of hazard and 0 is the lowest.) Although this difference may cause fear of confusion, it’s important to note that GHS number ranking does not factor into labels, but only on the SDS.
In OSHA’s version of GHS (participating countries are allowed to customize their own version), certain categories aren’t regulated; HazCom doesn’t recognize category 5 for acute toxicity, category 3 for corrosion and irritation, and category 2 for aspiration. So if you see these hazard categories on chemical shipments from overseas, know that OSHA only cares about higher rankings, such as 1-4 for acute toxicity, 1-2 for corrosion and irritation, and category 1 only for aspiration.
The 16 Categories and What They Include
Here are the 16 sections with key information to know regarding each:
Section 1: Identification
Includes the chemical, product name, and other names by which the substance is known. Also includes recommended uses, supplier contact, manufacturer/importer contact, emergency number, and any restrictions on use given by the supplier.
Section 2: Hazard(s) Identification
This section indicates what all the hazards associated with the substance are, including hazard classification, signal word, hazard statements, pictograms, precautionary statements, description of other hazards not otherwise classified, and for mixtures containing ingredients with unknown toxicity, the percentage of the mixture consisting of these ingredients.
Section 3: Composition/Information on Ingredients
This section identifies all the ingredients in the product, including impurities and stabilizers, and all chemicals including trade secrets. Substances listed contain the chemical name, common names/synonyms, CAS numbers, etc. Information on mixtures, including hazardous ingredients, trade secret information, and batch-to-batch variation information can be found here.
Section 4: First-Aid Measures
This section describes measures that should be given by untrained responders to victims of exposure to the chemical, including first aid instructions; description of symptoms or effects, including acute and delayed effects, and recommendations for immediate medical care and special treatment.
Section 5: Fire-Fighting Measures
Any recommendations for fighting a fire caused by the chemical are covered in this section, including fire-extinguishing equipment and techniques/equipment to be avoided in extinguishing a fire related to the chemical. This section also includes advice on specific hazards that develop from the fire and PPE recommendations for firefighters.
Section 6: Accidental Release Measures
In the event of spills, leaks, or unintended releases of any kind, refer to this section for information on containment/cleanup practices, personal precautions, PPE information, evacuation procedures, and consultation recommendations.
Section 7: Handling and Storage
Refer to this section for guidance on safe handling practices and conditions for safe storage of the chemical. Information on incompatible chemicals and industrial hygiene considerations are listed in this part of the SDS.
Section 8: Exposure Controls/Personal Protection
This part of the SDS indicates exposure limits, engineering controls, and PPE measures used for minimizing exposure to the chemical. It’s required that this section include OSHA permissible exposure limits (PELs), threshold limit values (TLVs) from the American Conference of Governmental Industrial Hygienists (ACGIH), and other exposure limits used or recommended by the chemical manufacturer, importer, or employer.
Section 9: Physical and Chemical Properties
Look for the following information in this section: appearance, flammability/explosive limits, odor, odor threshold, vapor pressure and density, pH, flammability (solid/gas), relative density, flash/boiling/melting/freezing point, solubility, evaporation rate, viscosity, ignition temperature, decomposition temperature, and partition coefficient: n-octano/water. Other information such as dust deflagration index for combustible dust, may also be added by the manufacturer.
Section 10: Stability and Reactivity
Both stability and reactivity are covered in this section. Specific test data for the reactivity of the chemical or class/family of the chemical might be included if it is relevant. Chemical stability information, such as that related to handling and storage, as well as necessary stabilizers and safety issues related to change in appearance are also included in this section. This section also includes other information such as the possibility of hazardous reactions and their conditions, incompatible materials, and decomposition products that may result from use, storage, or heating.
Section 11: Toxicological Information
This section covers toxicological and health effects available for the chemical, or indicates if that information is not available. Likely routes of exposure (inhalation, ingestion, skin and eye contact) are included, as well as effects and symptoms of short- and long-term exposure. In addition, numerical measures of toxicity such as the LD50 and the estimated amount expected to kill 50 percent of test animals in a single dose are required to be in this section. If the chemical is included in the National Toxicology Program (NTP) Report on Carcinogens or is listed as a potential carcinogen by OSHA or by the International Agency for Research on Cancer IARC Monographs, that information is required as well.
Section 12: Ecological Information (Not enforced by OSHA)
This section, which isn’t sanctioned by OSHA, is nonetheless critical information because it includes data about toxicity in the environment—harm to fish, algae, crustaceans, plants, birds, bees, etc. It notes whether the chemical has potential to persist and degrade and under which processes, test information on bioaccumulation, groundwater contamination potential, and other adverse effects.
Section 13: Disposal Considerations (Not enforced by OSHA)
This section isn’t sanctioned by OSHA but includes important information on how to dispose of the substance. It has information on appropriate disposal methods, proper containers, properties of the chemical that could affect disposal, precautions for incineration or landfill, and language discouraging sewage disposal. It should also refer the reader to Section 8 for information about exposure controls and PPE.
Section 14: Transport Information (Not enforced by OSHA)
Even though this section isn’t enforced by OSHA, it is very important to consult when transporting the substance by road, air, rail, or sea. Such classification information as UN shipping name and number, transport hazard class(es), packing group number (if applicable), environmental hazards (e.g., if it’s a marine pollutant according to the Maritime Dangerous Goods Code), guidance on transport in bulk, and any precautions which an employee should be aware of or must comply with regarding transport inside our outside their premises.
Section 15: Regulatory Information
Any regulatory information (national or regional) related to the chemical or mixture not stated elsewhere on the SDS is to be included in this section. This can include OSHA, DOT, EPA, or Consumer Product safety Commission regulations.
Section 16: Other Information
You’ll find version information in this section of the SDS, including when the SDS was prepared, when the last revision was made, and what changes were made to the previous version. If the changes made are not fully clear based on the information in this section, you can call the supplier for an explanation. Any other useful information may also be included in this section.
Additional GHS/HazCom 2012 Training Resources
We recommend you check out this OSHA HazCom SDS training document for a more comprehensive look at what OSHA requires. OSHA has also recently announced this special GHS training resources page that includes free “toolbox talks,” free online GHS training tutorials, and GHS training kits with DVDs.
HazCom Compliance Timeline
June 1, 2015—MANUFACTURERS, DISTRIBUTORS & IMPORTERS
Dec. 1, 2015—DISTRIBUTORS
June 1, 2016—EMPLOYERS
ANYTIME DURING TRANSITION—EMPLOYERS, MANUFACTURERS, & DISTRIBUTORS
OSHA’s recent decision to adopt elements of the UN’s Globally Harmonized System (GHS) for labeling chemicals will mean changes for most US industrial facilities. Our FREE HCS/HazCom 2012 Standards best practices guide will help you sort out what it means for your facility. Request yours today.