Oh Sheet! What You May Not Know About SDSs

Who Has to Be Trained?

See this guidance for understanding what you have to do for compliance with the hazard communication standard with GHS amendments.

Important SDS Facts You May Not Know

There’s time to train. All employers that use, handle, store chemicals have until December 1, 2013, to train employees about the new GHS-compliant chemical labels and SDSs.  

They’re already out there. Employers have already started to see the new GHS-compliant labels and SDSs in their workplaces. If you have, you should begin training employees to read and interpret the new labels and SDS immediately. Many employers may decide to train their employees how to read and interpret both the MSDS and SDS during the phase-in period.

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There are compliance options. During the phase-in period, employers are allowed choose to comply with:

  • The pre-GHS HazCom standard for MSDSs;
  • The revised standard with GHS for SDSs; or
  • Both the pre-GHS standard and the revised GHS standard at the same time

Only 1 set of sheets are required. OSHA recognizes that HazCom programs will go through a period of time where MSDSs/SDSs under both standards will be present in the workplace. This situation is acceptable to OSHA, and employers will not be required to maintain two sets of MSDSs/SDSs for compliance purposes.

SDS Format with GHS Amendments

After June 1, 2015, chemical manufacturers, importers, or other employers preparing the SDS must format it using consistent headings in a specified 16-section sequence. Here’s a heads up for employers on the new SDS format.

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The SDS will include at least the following section numbers and headings and associated information within each heading, in the order listed:

  • Section 1 Identification—includes product identifier, manufacturer or distributor name, address, phone number, emergency phone number, recommended use, and restrictions on use
  • Section 2 Hazard(s) identification—includes all hazards regarding the chemical and required label elements
  • Section 3 Composition/Information on ingredients—includes information on chemical ingredients and trade secret claims
  • Section 4 First-aid measures—includes important acute or delayed symptoms or effects and required treatment
  • Section 5 Fire-fighting measures—lists suitable extinguishing techniques, equipment, and chemical hazards from fire
  • Section 6 Accidental release measures—lists emergency procedures, protective equipment, and 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, threshold limit values (TLVs), appropriate engineering controls, and 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, and numerical measures of toxicity
  • Section 12 Ecological information*
  • Section 13 Disposal considerations*
  • Section 14 Transportation information*
  • Section 15 Regulatory information*
  • Section 16 Other information—includes date of preparation or last revision

* Notation concerning Sections 12 to 15: OSHA will not enforce the information requirements in Sections 12 to 15; however, the SDS must include at least the heading names for those sections.

See tomorrow’s Advisor for how the new GHS requirements will affect chemical label compliance for employers.

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