Navigating Through the Labyrinth of SDS Requirements

 

An Introduction to SDS Requirements

A Safety Data Sheet (SDS) is a technical and regulatory document that is used to describe the properties of a hazardous chemical. It is an important document for chemical safety in the workplace.

This article will cover SDS documents as described in the Hazard Communication section of the Code of Federal Regulations, for the United States of America, as part of the Occupational Safety and Health Administration (OSHA). The full text of the Hazard Communication Standard can be found at  29 CFR 1910.1200.

What is a Safety Data Sheet (SDS)?

The OSHA Definition of a Safety Data Sheet is:

Safety data sheet (SDS) means written or printed material concerning a hazardous chemical that is prepared in accordance with paragraph (g) of this section. - 29 CFR 1910.1200(c) “Safety data sheet (SDS)”

Paragraph (g) describes the contents of an SDS and the responsibilities of the different parties in the supply chain, including manufacturers/importers, distributors, and end-users.

What About a Material Safety Data Sheet? What is the Difference between an MSDS and an SDS?

The material safety data sheet used a now outdated format that had been used for the same purpose of describing the properties and risks of a hazardous chemical. The change in format and name took place with the Hazard Communication Standard revisions which went into effect May 25, 2012. OSHA allowed for an adjustment period of over three years, with SDS documents needing to be provided in place of MSDS documents by June 1, 2015, as explained in a standard interpretation letter. The change to the SDS format brought the United States regulations in line with the Global Harmonized Standard (GHS).

What is a Hazardous Chemical?

The OSHA Definition of a Hazardous Chemical is:

Hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified. - 29 CFR 1910.1200(c) “Hazardous chemical”

In simpler terms, for the purposes of workplace safety, a hazardous chemical is a substance that can cause physical damage or is harmful to human health.

Who is Responsible for Making an SDS?

Chemical manufacturers and importers are responsible for the creation of appropriate safety data sheets (SDS) for any hazardous chemicals they manufacture or import. A chemical manufacturer can develop the SDS in-house or use a third-party authoring company to develop one. A chemical importer may obtain an SDS from their foreign manufacturing partner, though the U.S. business is responsible for ensuring that the information is correct and is considered the responsible part for identification and legal liability purposes.

Chemical distributors and end-users, or any other employer that has employees exposed to hazardous chemicals, are responsible for ensuring that a proper SDS has been provided with each of the hazardous chemicals at the workplace. Any employer may choose to have a new SDS developed, such as for re-branding purposes or to generate a more general document if purchasing the same hazardous chemical from multiple vendors.

When Does an SDS Need to Be Updated?

In the latest regulations related to SDS by OSHA, there is no longer a mandatory update cycle. If new, significant information on the hazards of a chemical substance becomes known, there is a three-month period to update any effect documents.

Note that this only applies to US OSHA-regulated SDS documents. Mandatory update cycles may still apply in other jurisdictions. An SDS produced in one country may or may not be considered compliance in another country. 

Overview of SDS Sections

The sections of the SDS come from the guidelines of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS calls for an SDS to be divided into sixteen (16) sections.

Section 1: Identification

The product identifier is used in this section. This identifier is the name used for the chemical other than the substance name, such as a trade name, formula name, or common name. The product identifier on the SDS must match the product identifier used on the corresponding hazardous chemical label.

Other means of identification are also to be indicated in this section. This includes product names for sales purposes or any other alternate names the chemical may be referred to as.

The recommended use and any restrictions on use are indicated in this section.

The name, address, and telephone number of the manufacturer, supplier, or responsible party must also be provided on the label.

Additionally, an emergency contact number is also included in this section. The emergency contact number must fit the requirements of an emergency contact as given in the Department of Transport regulations. The emergency contact number must monitored at all times and answered by a person who is knowledgeable of the hazardous chemical(s) and has comprehensive emergency response information, or has immediate access to a person who has the knowledge.

Section 2: Hazard(s) Identification

This section includes the classification of the chemicals, including physical hazards, health hazards, and hazards not otherwise classified.

This section also includes the corresponding pictograms, hazard statements, and precautionary statements.

If any of the substances in a mixture are of unknown acute toxicity in a ≥1% concentration, a disclaimer statement must be included. This statement is that the mixture contains ingredient(s) of unknown acute toxicity, with the corresponding concentration of the ingredient(s).

Section 3: Composition/Information on Ingredients

For each substance that makes up a chemical, the following information is provided.

• Chemical Name
• Common Names and Synonyms
• CAS Number and other unique identifiers
• Impurities and stabilizing additives that are also classified as hazardous
• Exact Concentration or Concentration Range for all ingredients

The presentation of this information may differ if the originator has chosen to withhold information on one or more ingredients as a trade secret.

A Note on Trade Secrets Pertaining to SDS Composition Disclosure

The originator of an SDS may choose to withhold specific information about the identity or precise concentration of a hazardous chemical provided the following.

• There is a supported claim that the information is a trade secret.
• Information about the hazardous properties of the chemical is disclosed in the SDS.
• The SDS includes a statement that the specific information is being withheld.
• The specific information is made available to health professionals, employees, and designated representatives in accordance with the regulations.

 The full information on trade secrets pertaining to safety data sheets can be found at 29 CFR 1910.1200(i).

Section 4: First-Aid Measures

This section includes important information for rendering first aid in the event of exposure to the hazardous material covered by the SDS. This information includes a description of measures to be taken according to different routes of exposure, such as inhalation, skin contact, eye contact, and ingestion.

This section also includes important symptoms, both acute and delayed, as well as the signs that immediate medical attention will be needed and what special treatment may needed in the event of exposure.

Section 5: Fire-Fighting Measures

This section includes important response information in the event there is a fire involving the hazardous chemical. This information includes suitable and unsuitable extinguishing material, specific hazards arising from the chemical in a fire, and any special protective equipment and precautions for fire-fighters.

Section 6: Accidental Release Measures

This section contains information on how to respond in the event of an accidental release, such as a spill. This information includes precautions to be taken, protective equipment needed, and emergency procedures. Also included are the methods and materials needed for containment and cleanup.

Section 7: Handling and Storage

This section gives information about safe handling and storage practices for the material covered by the SDS. This information includes precautions to be taken for safe handling. This information also includes conditions for safe storage, including incompatibilities.

Section 8: Exposure Controls/Personal Protection

This section gives any specific exposure limits for the hazardous chemical as given by OSHA permissible exposure limit (PEL), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the SDS.

Additionally, this section includes any appropriate engineering controls and individual protection measures, such as personal protective equipment (PPE).

Section 9: Physical and Chemical Properties

This section lists all available physical and chemical properties, including but not limited to appearance, odor, melting point, and solubility.

Section 10: Stability and Reactivity

This section gives information about the stability and reactivity of the covered hazardous chemical. This includes information on the possibility of hazardous reactions and hazardous decomposition products, as well as incompatible materials and conditions to avoid.

Section 11: Toxicological Information

This section gives information both describing the toxicology of the hazardous chemical and the numerical measures for the toxicology. Information includes the likely routes of exposure and corresponding symptoms of exposure.

This section also includes whether the hazardous chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens or if it has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest edition), or by OSHA.

Section 12: Ecological Information

The information in this section is not regulated by OSHA and is considered non-mandatory for the purposes of regulatory compliance. As the information is required to conform to other regulations, including EPA and/or DOT requirements, it is considered good practice to include the information in the SDS.

This section includes ecotoxicity information, persistence, degradability, bio-accumulative potential, mobility in soil, and any other adverse ecological effects.

Section 13: Disposal Considerations

The information in this section is not regulated by OSHA and is considered non-mandatory. As the information is required to conform to other regulations, including EPA requirements, it is considered good practice to include the information in the SDS.

This section includes information about handling waste residues from the hazardous chemical. This includes a description of waste residues, information on their safe handling, and methods of disposal. This includes the disposal of any contaminated packaging.

Section 14: Transport Information

The information in this section is not regulated by OSHA and is considered non-mandatory. As the information is required to conform to other regulations, primarily DOT requirements, it is considered good practice to include the information in the SDS.

This section includes information about any applicable transportation information for the hazardous chemical. Please note that a hazardous material may not be classified as hazardous for transportation purposes.

This section includes the UN number, UN proper shipping name, transport hazard classes, packing group, environmental hazards, and any applicable special precautions.

Section 15: Regulatory Information

The information in this section is not regulated by OSHA and is considered non-mandatory. As the information is required to conform to other regulations, it is considered good practice to include the information in the SDS.

This section includes any other applicable regulatory information for the hazardous chemical and/or its ingredients. This includes listing on any disclosure lists not covered by the other sections, such as a California Proposition 65 disclosure.

Section 16: Other Information

This section includes the date of preparation or last revision of the SDS. Many SDS authors also include a list of citations and databanks utilized in the SDS creation in this section.

Importance of Complying with SDS Requirements

Legal and Regulatory Compliance

The Hazard Communication Standard, which covers SDS documents, was the 2nd most commonly cited regulation in 2022 on the federal level. OSHA does enforce the regulations around proper communication of what chemical hazards are in the workplace. This includes having proper SDS documents and chemical labels in place.

Minimizing Risk and Occupational Hazards

In addition to being legally required, SDS documents provide important information for maintaining a safe, and therefore productive, work environment. Knowing what hazards are present enables proper planning and safety measures to be put into place. 

Utilizing SDS Information for Risk Assessments

Performing a risk assessment requires knowing what the risks are. An SDS provides the majority of the information needed, containing the physical and health hazards of a given hazardous chemical, as well as recommendations for the engineering controls and personal protective equipment needed. Combining this basis provided with the particular setup and needs of a given workplace allows for a good risk assessment to be performed.

Training Employees on SDS Awareness and Understanding

Employees should be trained on how to read an SDS, both as an OSHA requirement and general good practice for chemical safety. This includes what information is contained in each of the sixteen sections and the meaning of the GHS symbols. 

Maintaining an SDS Binder

An SDS Binder serves as a convenient reference location for all SDS documents for hazardous chemicals used in the workplace. The binder can be a physical binder or an electronic folder. With either format, the SDS documents need to be readily available, with access unimpeded by a key or password.

Conclusion

A safety data sheet (SDS) is an important tool for working safely with hazardous chemicals. Understanding SDS requirements is key to implementing their proper use in the workplace.

Learn more about the importance of OSHA even when Self-Employed, and take advantage of the official OSHA eTools to aid in compliance.