HAZCOM: 4 STEPS FOR COMPLYING WITH MSDS REQUIREMENT

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: HazCom |

 

Making sure the information in a Material Safety Data Sheet (MSDS) is accurate, complete and up to date is a real pain in the neck. But here’s a true story to remind you of why it’s so important.

An Avoidable Tragedy

The story takes place in 2001 at a steel mill in Chesterton, Indiana. The mill keeps an MSDS for the hazardous substances on site. That includes coke oven gas condensate. The MSDS says that coke oven gas condensate consists principally of water. This is true. But the MSDS omits a piece of vital information: the fact that the stuff is flammable, especially at lower temperatures.

This turns out to be a fatal omission. Steel workers at the mill are removing a leaky pipe containing coke oven gas condensate. It’s February and temperatures have been brutally cold. The cold temperatures have frozen the water in the condensate. But the flammable parts are still liquid and able to travel through the pipes. They’re what’s leaking out of the pipe. When the workers start to remove the pipe, the flammable liquid spritzes out and soaks two of them. It also sprays all over a space heater and heat lamp, causing the fluid to ignite. As the flames reach the valve of the pipe the workers are trying to remove, there’s a blast and more flammable liquid sprays everywhere. Two workers are killed.

The U.S. Chemical Safety and Hazardous Investigation Board (CSB), an independent federal agency, investigates the accident and concludes that describing the condensate’s flammability in the MSDS might have prevented the accident and saved the workers’ lives.

MSDS Inaccuracies Lead to Injuries, Liability

The OSHA Hazard Communication Standard requires employers to keep an MSDS for each hazardous chemical they know to be present at their workplace to which a worker may be exposed. The MSDS describes the chemical’s hazards and physical properties and lists safeguards to take when using or being around the chemical. This is information workers need to protect themselves. That’s why inaccuracies in and omissions from the MSDS can be so dangerous. In addition to fatalities and serious injuries (like in the Indiana case), not including complete and accurate information in the MSDS can lead to OSHA and OHS citations.

Unfortunately, the MSDS is a technical document and the OSHA rules governing their contents can be pretty confusing. Consequently, MSDS mistakes happen all the time. Last year, OSHA handed out more citations under the Hazard Communication Standard (including MSDS violations) than under any other standard except for Construction Scaffolding.

Bottom Line: Making sure your MSDSs are complete and accurate is one of the most important things you can do to prevent accidents and avoid citations.

Four Steps to Protect Yourself

1. Appoint Central MSDS Administrator

OSHA experts say it’s important to designate a point person who’s responsible for keeping track of MSDS. This person should:

  • Make sure there’s a current and complete MSDS for each hazardous substance at your workplace;
  • Keep an accurate log of hazardous substances; and
  • Ensure that workers have ready access to MSDSs.

2. Keep MSDS Database Up to Date

OSHA requires chemical manufacturers and importers to send you an MSDS at first shipment and whenever there’s a change. Even so, MSDS information at many companies is out of date. That may be because manufacturers send only the original MSDS and not the revised version. Or it may be because the revised MSDS gets lost or misplaced at shipment, especially if the person who takes shipment isn’t familiar with the MSDS system.

Tip: Go through each MSDS at your workplace and make sure it’s current. If it’s more than a year or two old, you should ask the manufacturer to send a revised one or get it from the company’s website. Also try: www.msdsonline.com and www.hazard.com/msds/index.php.

3. Make Sure MSDS Has All Required Information

An MSDS may not list all the information OSHA requires, especially if the MSDS was prepared on site.  Sometimes the omitted information can be critical, like in the Chesterton incident. So go through each MSDS at your workplace and ensure it contains:

  • Chemical and common names of all ingredients considered health hazards;
  • Physical and chemical characteristics of hazardous chemicals such as vapor pressure and flash point;
  • Physical hazards such as potential for fire or explosion;
  • Health hazards including signs and symptoms of exposure and medical conditions that exposure may aggravate;
  • Primary routes of entry into human beings;
  • Permissible exposure limits;
  • Whether the chemical is considered a carcinogen;
  • Precautions for safe use and handling including appropriate protective measures during repair and maintenance of contaminated equipment and procedures for spills or leaks;
  • Control measures such as appropriate protective equipment and work practices;
  • Emergency and first aid procedures; and
  • Date of preparation of the MSDS and contact information of company or person who prepared the MSDS.

Tip: It usually takes at least three pages to fit in all this information. If an MSDS is shorter than three pages, it could be an indicator that certain information is missing..

4. Avoid Inconsistencies and Techno-Babble

Check each MSDS for inconsistencies (for example, calling a product a liquid in one place and a gas in another). Also be on the lookout for an overload of dense technical jargon. Remember that an MSDS won’t help if workers can’t understand it.  To make the MSDS easier to read, consider creating a “summary sheet” that highlights the product’s properties and hazards. But be careful: If you change the substance of an MSDS prepared by a manufacturer, you may become liable for the contents.

Tip: To make the MSDS easier to understand, consider creating a “summary sheet” that highlights the hazards of specific chemicals.  But attach the summary to the actual MSDS so workers have access to all the information if they want it.

 

 

 
 
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