Manufacturers and importers of hazardous chemicals have
until June 1,
2015 to update their labels and material safety data sheets to be in
compliance with the Hazard Communication Standard (HCS) final rule promulgated
by the Occupational Safety and Health Administration (OSHA). While you’re
patiently waiting for manufacturers to conduct the revisions to labels and
updating material safety data sheets to reflect the 16-section format required
for Safety Data Sheets (SDS), you still have to train your employees in the new
label elements and new SDS format.
OSHA has put together Quick Cards for sample
labels and SDS,
explaining the new requirements, but some employees and safety professionals
may find it difficult to train employees without real, concrete examples. Many
manufacturers and importers may also be moving slowly on their revisions due to
the perceived difficulty of completing the revisions.
To assist safety professionals and industrial hygienists
in their training, here’s some do-it-yourself (DIY) 3-step guidance on
preparing your own labels and SDS.
Step 1: Review the requirements for SDS and labels.
Please note that OSHA cannot enforce the
content of Sections 12 to 15 of the SDS, as these sections are enforced by
other regulatory agencies like the U.S. Environmental Protection Agency (EPA) and
U.S. Department of Transportation (DOT) that have not yet adopted GHS.
Step 2: Figure out the hazard classification and category
of the substance or mixture.
This is the hardest part of SDS and label preparation –
figuring out how to properly classify the substance or mixture. If you want to
read through GHS Part
2: Physical Hazards and Part
3: Health Hazards to get an idea of the complexity of this task, you can,
but you may find it overwhelming.
You’ll need some knowledge of toxicology and management
of hazardous materials to complete this task. If you’re lucky, you’ll find a
SDS already prepared by another manufacturer (usually with international
capability who already has GHS-compliant SDS) that contains the hazard
classification of the substance or mixture.
You have to assess if your chemical constitutes a
physical hazard, a health hazard, or both. Some examples of physical and health
hazards are included below.
Physical Hazard
Explosives
Flammable Gases
Flammable Aerosols
Gases Under Pressure
Flammable Liquids
Self-Reactive Substances and Mixtures
Pyrophoric Solids
Oxidizing Liquids
Organic Peroxides
Corrosive to Metals
Health Hazard
Acute
Toxicity
Skin Corrosion/Irritation
Serious Eye Damage/Eye Irritation
Respiratory or Skin Sensitization
Germ Cell Mutagenicity
Carcinogenicity
Reproductive Toxicity
Specific Target Organ Toxicity – Single Exposure
Specific Target Organ Toxicity – Repeated Exposure
Aspiration Hazard
Physical Hazard: Here’s where the hazardous
materials management knowledge will come in handy. You’ll want to find the
upper and lower flammable limit/range of your chemical or mixture at standard
pressure; understand whether you have a compressed gas, liquefied gas,
refrigerated liquefied gas, or dissolved gas; know the flash point for your
chemical or mixture; research the burning rate of your flammable solid;
research the heat of decomposition; and know the corrosion rate or steel and/or
aluminum.
Health Hazard: This is where knowledge of
toxicology and ability to search various institutional databases will be
useful.
Acute Toxicity:
look up the various lethal doses for each anticipated exposure route (oral,
inhalation, dermal, etc.). The LD50 indicates the lethal dose in 50% of test subjects
(oral, dermal, and other routes) and the LC50 indicates the lethal
concentration in 50% of test subjects (inhalation route).
Useful sources for health hazards:
- National Institutes of Health ToxNet – Hazardous Substances Data
Bank (HSDB): Look up the chemical(s) by Chemical Abstract Service (CAS)
number or chemical name. This provides information on human health effects,
emergency medical treatment, animal toxicity studies, environmental fate,
chemical/physical properties, chemical safety and handling, and occupational
exposure standards.
- Centers for Disease Control and Prevention (CDC), National Institute for Occupational Safety
and Health (NIOSH) Pocket Guide to Chemical Hazards: Look up the
chemical(s) by CAS number of chemical name. This provides the synonyms and
trade names, conversion rates, DOT Emergency Response Guide number, Immediately
Dangerous to Life and Health (ILDH) concentration, recommended measurement
methods, exposure limits, physical description, exposure routes, symptoms, incompatibilities
and reactivities, personal protection, and first aid recommendations.
- Registry of Toxic Effects of Chemical Substances (RTECS), linked from
NIOSH Pocket Guide to Chemical Hazards: This provides skin and eye irritation
data, mutation data, reproductive effects, and acute toxicity data.
- OSHA
Occupational Chemical Database: This compiles information from the DOT
Emergency Response Guidebook, NIOSH
Pocket Guide to Chemical Hazards, and OSHA
Chemical Sampling Information webpage.
- Agency for Toxic Substances and Disease Registry (ATSDR) Toxic Substances Portal:
Provides toxicological profiles, public health concerns, and health effects;
search by CAS number of chemical name.
- ATSDR Medical
Management Guidelines: Use for basic chemical and exposure information, a
summary of potential health effects (acute and chronic), routes of exposure,
and incompatibilities.
Step 3: Start Writing the SDS.
Once you have the hazard classification for each chemical
or mixture, the rest of the SDS is mostly data gathering.
Section
1 – Identification
Include the product identifier (as used on the label), other means of
identification, recommended use, supplier’s details, and emergency phone
number.
Section 2 – Hazard Identification
Using the hazard classification, go to Annex 3 for the “Codification
of Hazard Statements, Codification and Use of Precautionary Statements and
Examples of Precautionary Pictograms.” Look through the listed Hazard
Statement codes for physical hazards in Table A3.1.1 and it will tell you what
hazard statements and pictograms belong on the SDS and label based on the
hazard class. There are also tables for the various Precautionary Statements
(prevention, response, storage and disposal). Or, to make it simpler, on page 336
of Annex 3, there is a series of tables encompassing much of the rest of the
Annex showing the required signal word, hazard statement, symbol, and
precautionary statement(s) based on the hazard classification and associated
hazard category. It makes Section 2 very simple to accomplish.
Pictograms can be downloaded as .JPG files from OSHA here.
 |
| Health Hazard Pictogram |
Section 3 – Composition/Information on Ingredients
This should be present on the original material safety
data sheet you are converting to SDS format.
Section 4 – First Aid Measures
For information about the most important symptoms (acute
and delayed), and indication of immediate medical attention and special treatment
needed, the sources listed above for researching health hazards will be useful.
Section 5 – Fire-Fighting Measures
Section 6 – Accidental Release Measures
Information from this section can be easily obtained from
the DOT Emergency Response
Guidebook, by finding the Guide number that matches the chemical(s) on your
SDS and reviewing the emergency response spill or leak information.
Section 7 – Handling and Storage
Section 8 – Exposure Controls/Personal Protection
Include relevant exposure limits here. It is best
practice to include the following for each chemical, as applicable:
This section should also include information if the
chemical(s) is a carcinogen, and include engineering controls and personal
protective equipment (PPE) for the anticipated routes of entry (eye/face
protection, skin protection, respiratory protection).
Useful resources for determining the proper PPE are
included below:
Section 9 – Physical and Chemical Properties
This should be present on the original material safety
data sheet you are converting to SDS format. Alternatively, the information on
each chemical(s) may be able to be obtained from the ToxNet HSDB and the International Chemical Safety
Cards by the CDC. The International Chemical Safety Cards can be searched
by CAS number, chemical name, RTECS number, and UN number.
Section 10 – Stability and Reactivity
Section 11 – Toxicological Information
Section 12 – Ecological Information, Section 13 –
Disposal Consideration, Section 14 – Transport Information, and Section 15 –
Regulatory Information
These sections are not required by OSHA at this time; you
can include the information or state “This section is not required according to
29 CFR 1910.1200(g)(2)” if your SDS is being developed for internal use only.
Section 16 – Other Information
This section can include the date of preparation of the
last revision of the SDS, literature references and sources for data used to compile
information for the SDS, a key for abbreviations, National Fire Protection
Association (NFPA) and Hazardous Materials Information System (HMIS) ratings,
and any internal “safety notices” or legalese you’re required to place at the
end of every SDS by your corporate counsel.
Completion and Review
Request that a colleague review the SDS for typos and
accuracy. Make sure the hazard statements and precautionary statements are
correct for the hazard classification and associated category you have selected
for the chemical(s) on the SDS. Double check CAS numbers and chemical concentrations.
Once the SDS revision is complete, if you have a need for
facility-specific labels, this is a simple process. All the information you
need for the label can be copy/pasted from the SDS to the label. The pictograms
can be downloaded from OSHA’s Hazard
Communication website for use in container labels. You’ll be surprised how
much you’ll learn when completing the SDS revision.
