GHS Changes

How to Comply with New SDS Requirements

Date First Published on SafetySmart Compliance: April 17th, 2012
Topics: HazCom |

By Glenn Demby, Esq. – April 15, 2012 – For many employers, complying with the new MSDS/SDS requirements will be the toughest part of GHS. Here’s what you have to do and when.

COMPARING MSDS/SDS REQUIREMENTS

Current MSDS Rules

 Employers must obtain from chemical manufacturer or importer (or prepare themselves) and ensure all employees have access in their workplace to a Material Safety Data Sheet for each hazardous chemical in the workplace listing 13 pieces of information about the product:

(Instructions: Just scroll through this list if you already know the MSDS information requirements.)
1. Its chemical identity (as noted on label)

2. (a) For single substance chemicals, its chemical & common names

(b) For mixture tested as a whole:
i. Common name of mixture; and
ii. Chemical & common names of ingredient chemicals contributing to mixture’s hazard

(c) For mixture not tested as a whole:
i. Chemical & common names of ingredients that are health hazards & constitute 1% or greater (or .1% if a carcinogen) of composition
ii. Chemical & common names of ingredients that are health hazards & constitute less than 1% (or .1% if a carcinogen) of mixture composition when there’s evidence that ingredients could be released from mixture in concentrations above the OSHA PEL or ACGIH TLV, or could present a health risk to employees
iii. Chemical & common names of ingredients that “present a physical hazard when present in the mixture”

3. Its physical & chemical characteristics, e.g., flash point

4. Its physical hazards

5. Its health hazards including signs & symptoms of exposure & medical conditions that exposure may aggravate

6. Primary routes of entry

7. PEL, ACGIH TLV & other exposure limits recommended by manufacturer or importer (or employer preparing MSDS

8. Whether chemical is listed in the National Toxicology Program (NTP) Annual Report on Carcinogens or is a potential carcinogen according to OSHA or latest editions of the International Agency for Research on Cancer (IARC) Monographs

9. Safe handling & use practices, including hygienic practices, protective measures during repair & maintenance of contaminated equipment & procedures for clean-up of spills/leaks

10. Control measures, including engineering controls, work practices or PPE

11. Emergency & first aid procedures

12. Date MSDS was prepared & most recently changed

13. Name, address & phone number of manufacturer or importer that prepared MSDS and/or “other responsible party” who can provide additional information about the product & emergency procedures.

GHS SDS Rules

Employers must obtain from chemical manufacturer or importer (or prepare themselves) and ensure all employees have access in their workplace to a Safety Data Sheet for each hazardous chemical in the workplace listing information about the product in 16 sections (note: Sections 12-15 are non-mandatory)

(Instructions: Just scroll through this list if you already know the SDS information requirements.):

 

Section 1. Identification, i.e.:

(a)        Product identifier stated on label

(b)        Other means of identification

(c)        Use/restrictions on use

(d)       Name, address, telephone of manufacturer, importer or responsible party

(e)        Emergency phone number

Section 2. Hazard Identification, i.e.:

(a)        GHS chemical classification

(b)        Signal word, hazard statement & precautionary statement

(c)        Description of hazards not otherwise classified

(d)       Statement of % of mixture not classified for mixtures not tested as a whole consisting of ingredients of unknown toxicity in concentrations of 1% or more

Section 3. Composition/Ingredients:

For Substances:

(a)        Chemical name

(b)        Common name & synonyms

(c)        CAS number/other unique identifier

(d)       Impurities & stabilizing additives classified & contributing to substance’s classification

 

For Mixtures: 

(a)        Same information required for substances above

(b)        Chemical name & concentration percentage or range for all ingredients classified as hazards present above their cut-off/concentration limits or  that present a health risk below cut-off/concentration limits

(c)        Concentration percentage unless it’s a trade secret).

For Chemicals Where Trade Secret Protection Is Claimed:  

(a)        Statement “that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a trade secret”)

Section 4. First Aid Measures, i.e.:

(a)        Necessary measures listed by route of exposure—inhalation, skin & eye contact & ingestion

(b)        Key symptoms/effects, both acute & delayed

(c)        Whether immediate medical attention or special treatment needed

Section 5. Fire-fighting Measures, i.e.:

(a)        Suitable/unsuitable extinguishing media

(b)        Specific hazards arising from chemical

(c)        Special fire-fighting protective equipment & precautions needed

Section 6. Accidental Release Measures, i.e.:

(a)        PPE, precautions & emergency procedures

(b)        Containment & clean-up methods/materials

Section 7. Handling and Storage, i.e.:

(a)        Safe handling measures

(b)        Safe storage conditions, including any incompatibilities

Section 8. Exposure Controls/Personal Protection, i.e.:

(a)        OSHA’s PEL, ACGIH TLV & other exposure limits recommended by manufacturer, importer or employer that prepares SDS

(b)        Engineering controls

(c)        PPE & other individual protection measures

Section 9. Physical and Chemical Properties, i.e.:

(a)        Appearance (physical state, color, etc.)

(b)        Odor

(c)        Odor threshold

(d)       pH

(e)        Melting point/freezing point

(f)        Initial boiling point & boiling range

(g)        Flash point

(h)        Evaporation rate

(i)         Flammability (solid, gas)

(j)         Upper/lower flammability or explosive limits

(k)        Vapor pressure

(l)         Vapor density

(m)       Relative density

(n)        Solubility(ies)

(o)        Partition coefficient: n-octanol/water

(p)        Auto-ignition temperature

(q)        Decomposition temperature

(r)        Viscosity

Section 10. Stability and Reactivity, i.e.:

(a)        Reactivity

(b)        Chemical stability

(c)        Possibility of hazardous reactions

(d)       Conditions to avoid (e.g. static discharge, shock, or vibration)

(e)        Incompatible materials

(f)         Hazardous decomposition products

Section 11. Toxicological Information, i.e., description of various toxicological (health) effects and available data used to identify them, including information about:

(a)        Likely route(s) of exposure—inhalation, ingestion, skin & eye contact

(b)        Symptoms related to chemical’s physical, chemical & toxicological characteristics

(c)        Immediate, delayed & chronic effects of short or long term exposure

(d)       Numerical measures of toxicity, e.g., acute toxicity estimates

(e)        Whether it’s a carcinogen in NTP Report listing or potential carcinogen as per latest edition of IARC Monograph or OSHA

Section 12. (Nonmandatory) Ecological Information, i.e.:

(a)        “Ecotoxicity (aquatic & terrestrial)

(b)        Persistence & degradability

(c)        Bioaccumulative potential

(d)       Mobility in soil

(e)        “Other adverse effects, e.g., hazardous to ozone layer

Section 13. (Nonmandatory) Disposal Considerations, i.e., waste residue description, methods for safe handling and disposal (including disposal of contaminated packaging)

Section 14. (Nonmandatory) Transport Information, i.e.:

(a)        UN number

(b)        UN proper shipping name

(c)        Transport hazard class(es)

(d)       Packing group, if applicable

(e)        Environmental hazards, e.g., marine pollutant

(f)        Transport in bulk (according to Annex II of MARPOL 73/78 & IBC Code)

(g)        Special precautions for transporting chemical within or outside premises

Section 15. (Nonmandatory) Regulatory Information, i.e., any safety, health and environmental regulations that apply to the product

Section 16. Other: Preparation or Revision Date, i.e., date SDS was prepared or most recently changed.

COMPLIANCE TIMELINE

May 25, 2012 is the date GHS officially takes effect. June 1, 2016 is the date all GHS rules must be followed. During the interim transition period, both rules will be in effect. In other words, during that period you can comply with either current MSDS or new SDS requirements.

MSDS/SDS Compliance Timeline

March 26 to May 25, 2012

May 25, 2012 to June 1, 2016

After June 1, 2016

MSDS

MSDS or SDS

SDS

But another important deadline will occur during the transition period: By June 1, 2015, manufacturers and importers of hazardous chemicals must re-classify their products and create an SDS for each one. (That’s also the deadline to prepare your own SDS if you’re one of the few employers that create their own MSDSs.)

What this means is that both MSDSs and SDSs will be in circulation, starting June 1, 2015 to June 1, 2016. And because some manufacturers and importers will replace MSDSs with SDSs early—in fact, some already have—be prepared to deal with both MSDSs and SDSs from now thru June 1, 2016.

Remember that as long as you have either an old school MSDS or a newfangled SDS, you’ll be in compliance. But once the transition period ends on June 1, 2016, the MSDS will be retired and only an SDS will do.

5 STEPS TO TAKE

  1. From now thru June 1, 2016, make sure each hazardous chemical has either an appropriate MSDS* or SDS**;
  1. By December 1, 2013, make sure all employees exposed to hazardous chemicals have been trained on how to use the new SDSs—and GHS labels;
  1. No later than June 1, 2015, start asking suppliers that provide you hazardous chemicals requiring an MSDS for an SDS** to replace the MSDS* with;
  1. By June 1, 2016, make sure:
    1. You have an appropriate SDS** for each hazardous chemical at your workplace; and
    1. You replace all MSDSs in your current MSDS binder or electronic system with an appropriate SDS**.
  1. On June 1, 2016 and thereafter, make sure each shipment of hazardous chemicals you receive from suppliers includes an appropriate SDS*.

 

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* Use the Insider MSDS Checklist to verify that all MSDSs include all the required information.

** Use the Insider SDS Checklist to verify that all SDSs include all the required information.

 
 
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