This guide is for Employers that acquire hazardous chemicals from outside suppliers—as opposed to employers that manufacture or import those chemicals themselves.
One of the biggest compliance challenges of Hazcom is to get an appropriate Material Safety Data Sheet (MSDS) for each hazardous chemical you use, handle or store in your workplace. You’ll face the same challenge under GHS. Here’s a look at what you’ll have to do:
Current MSDS Rules
Under the current OSHA Hazard Communication Standard, it’s the employer’s responsibility to ensure that each shipment of products labeled as hazardous chemicals have an appropriate MSDS. There are 2 ways you can meet this requirement:
Manufacturers and importers must furnish an MSDS for each shipment of hazardous chemicals at or before shipment. If for some reason they don’t, employers must contact the supplier to request one “as soon as possible.”
Manufacturers and importers also have to update the MSDS within 3 months of becoming aware of new hazards associated with the chemical or ways to protect against them, and include the updated MSDS with the first shipment after it’s revised. If you discover that an MSDS is out of date, you must request a revised version from the supplier.
GHS SDS Rules
Under GHS, MSDSs will become SDSs—Safety Data Sheets (the “M” is going away); the newfangled SDS will also have to list different kinds of information and in a different format. (Click on the link to see the differences.) But what isn’t changing is your responsibility to ensure each shipment labeled hazardous chemicals has an appropriate SDS. The same options apply:
As under current rules, manufacturers and importers must furnish an SDS for each shipment of hazardous chemicals at or before shipment. If for some reason they don’t, employers must contact the supplier to request one “as soon as possible.”
Also as under current rules, manufacturers and importers must update the SDS within 3 months of becoming aware of new hazards associated with the chemical or ways to protect against them, and include the updated SDS with the first shipment after it’s revised. If you discover that an SDS is out of date, you must request a revised version from the supplier.
How to Comply
Follow Current MSDS Rules
GHS officially takes effect on May 25, 2012. Until that date, you must comply with current MSDS rules.
Follow Either Current MSDS or GHS SDS Rules
During the 4-year transition period of May 25, 2012 to June 1, 2016, you must ensure that each hazardous chemical has either an MSDS or SDS. In other words, you can follow the rules in either of the boxes above.
During this transition period, you should be prepared to have both old school MSDSs and newfangled SDSs at your workplace at the same time.
Explanation: GHS requires manufacturers and importers to re-classify their products using new GHS criteria; once re-classification is complete, they must prepare an SDS listing the key hazard information about the product. The deadline: June 1, 2015.
Of course, some manufacturers and importers will complete re-classification and prepare SDS before the deadline; in fact, some already have. So the shipments of hazardous chemicals you receive from now until June 1, 2015 may have either an MSDS or SDS. All shipments made after June 1, 2015, will have to have an SDS.
But it’s going to take time for employers and downstream users to catch up. Sure, you’ll get an SDS with new shipments after June 1, 2015; but for a period, your workplace will contain hazardous chemicals that were shipped before June 1, 2015.
Result: You’re likely to have only an MSDS for these products. The good news is that you have another 12 months—until June 1, 2016—to ensure that all MSDSs are replaced with SDSs.
Follow GHS SDS Rules
After June 1, 2016, the MSDS becomes extinct and you must ensure that each hazardous chemical in your workplace has an SDS and only an SDS.
How to Replace MSDS with SDS
1. Identify all the hazardous chemicals used in your workplace that currently require an MSDS—refer to the hazardous chemicals inventory attached to your written Hazard Communication Program (HCP) (click here to find out how to create a hazardous chemicals inventory);
2. If a hazardous chemical requires an MSDS under current Hazcom rules, you can be pretty sure it’s going to require an SDS under GHS;
3. From now through June 1, 2016, make sure each hazardous chemical in your workplace has either:
4. From now through June 1, 2015, if you discover that a hazardous chemical doesn’t have an MSDS or SDS or does have an MSDS or SDS that doesn’t include all the required information, contact the supplier to request an appropriately completed MSDS or SDS;
A. Document your request either by copy of a letter or note regarding telephone conversations that lists the following information (Click here for a Model MSDS/SDS Request Record you can adapt):
B. If you don’t get a satisfactory response from your supplier, contact your local OSHA Area Office for help in getting the MSDS/SDS;
C. Keep copies of your request documents readily accessible so you can prove you requested the MSDS/SDS.
5. Starting June 1, 2015, make sure all new shipments of hazardous chemicals you receive include an appropriate SDS (and only an SDS) (click here for a checklist you can use to ensure the SDSs you’re using list all the information required by GHS);
6. Starting June 1, 2015, , if you discover that a hazardous chemical doesn’t have an SDS or does have an SDS that doesn’t include all the required information, contact the supplier to request an appropriately completed SDS;
A. Document your request “either by copy of a letter or note regarding telephone conversations” that lists the following information (Click here for a Model MSDS/SDS Request Record you can adapt):
7. By June 1, 2016, replace all MSDSs with SDSs, i.e., make sure all hazardous chemicals that required an MSDS now have an appropriate SDS (click here for a checklist you can use to ensure the SDSs you’re using list all the information required by GHS).
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