Making Sense of a Safety Data Sheet
According to OSHA, employers must ensure that Safety Data Sheets are readily accessible to employees for all hazardous chemicals in their workplace, and employees should have immediate access to the information without leaving their work area when needed, even during a power outage or other emergency.
YouTube, federal OSHA's www.osha.gov, the American Chemical Society's homepage, the NIOSH Pocket Guide to Chemical Hazards—there are too many good chemical safety resources at your and my fingertips to list them all. This is a good thing for all of us, of course.
One thing that U.S. companies' employees who are working with potential hazardous chemicals should know by now is how to read and understand a Safety Data Sheet. After all, the first GHS deadline set out in the OSHA revised Hazard Communication Standard was about employee training on chemical labels and SDSs. Employers that already had done a good job of ensuring employees understood the hazards of chemicals they used and handled were in good shape as that initial deadline passed, even if updated SDSs from their suppliers weren’t available as quickly as expected.
Still, OSHA estimates the new standard applies to 43 million workers at more than 5 million workplaces overall. All of those employers had years to prepare for the new safety data sheets and labels, but surely some workers haven’t been trained to the competency level they should be, or newcomers' training might be coming up. So a short course on the SDS sections is in order. There are 16 in all, four of which are not mandatory, per OSHA.
Section 1: Product/Chemical Identification
This section lists the chemical's recommended uses, the supplier's contact information and emergency phone number, and common names and synonyms for the product.
Section 2: Hazard Identification
This section provides the hazard classification of the chemical, along with the signal word, hazard statements, pictograms, and precautionary statement(s).
Section 3: Composition of the Chemical
This section identifies the chemical’s ingredients and contains information on mixtures, including the percentages of ingredients that are classified as health hazards.
Section 4: First Aid Measures
Information about important symptoms or effects is found in this section, with first aid instructions listed by relevant routes of exposure (inhalation, contact with skin and eyes, and ingestion). It will list any symptom that is acute or delayed and recommendations for immediate medical care and special treatment, if needed.
Section 5: Firefighting
Workers will learn from information in this section how to fight a fire involving this chemical. It will list recommendations for extinguishing equipment to be used and, crucially, equipment that is not appropriate. Recommendations about special protective equipment or precautions for firefighting personnel are listed here.
Section 6: Spills, Leaks, Cleanup
This section details what to do to clean up spills and leaks of this substance, along with the emergency procedures to follow and proper methods of containment and decontamination.
Emergency procedures, including instructions for evacuations, would be in this section.
Section 7: Handling and Storage
Precautions for safe handling of the chemical and storing it, including incompatibilities, are listed in this section. Specific storage requirements, such as ventilation, are in this section, as are general hygiene practices (such as eating, drinking, and smoking prohibited in the work area).
Section 8: Exposure Controls and PPE
All 16 sections of the Safety Data Sheet are important, but this one is a key section for the safety and health of workers who will be or may be exposed to chemicals at work: This section will list OSHA's Permissible Exposure Limits (PELs), ACGIH Threshold Limit Values, and any other exposure limit recommended by the manufacturer, importer, or employer preparing the SDS. This section also details PPE to be worn when handling the chemical and appropriate engineering controls to employ.
Section 9: Physical and Chemical Properties
Upper and lower flammability or explosive limits, vapor pressure, melting point and freezing point, flash point, evaporation rate, and many other physical and chemical properties will be listed here.
Section 10: Stability and Reactivity
In this section is information about specific test data for the chemical, as well as an indication of whether it is stable or unstable under normal ambient temperature and conditions while being handled or in storage.
Section 11: Toxicology Information
Information on likely routes of exposure is included in this section, which should indicate if the information is unknown; delayed, immediate, and chronic effects from short- and long-term exposures also will be listed, along with numerical measures of toxicity and descriptions of symptoms associated with exposure, from the least to the most severe exposures. And if the chemical has been found to be a potential carcinogen, that information will be displayed here.
Sections 12-15 (non-mandatory, meaning OSHA does not enforce these sections): Ecological Information, Disposal, Transport, Other Regulatory Information
If they should need it, in these sections workers will find information on the chemical's environmental impacts and persistence in the environment. Proper disposal practices are lined in Section 13, including descriptions of appropriate disposal containers to use for it. Section 14 covers classification information when transporting hazardous chemicals by road, air, rail, or sea—such as transport hazard classes, guidance on bulk transport, and special precautions (if any). Section 15 will contain regulatory information for the chemical and mixtures, such as OSHA, DOT, EPA, or Consumer Product Safety Commission regulations.
Section 16: Additional Information
In this section, workers will find the date when this SDS was prepared or most recently updated. And it may include where the changes have been made from the previous version.
HazCom Enforcement
According to OSHA, employers must ensure that Safety Data Sheets are readily accessible to employees for all hazardous chemicals in their workplace, and employees should have immediate access to the information without leaving their work area when needed, even during a power outage or other emergency. Employers may choose to designate some employee who is responsible for obtaining and maintaining the SDSs, OSHA points out.
This is important because the Hazard Communication standard remains near the top of OSHA's annual Top Ten most-cited standards lists. For fiscal year 2015 (Oct. 1, 2014, through Sept. 30, 2015), it ranked second overall and first among the standards applying to general industry:
- Fall protection, 1926.501
- Hazard Communication, 1910.1200
- Scaffolding, 1926.451
- Respiratory protection, 1910.134
- Lockout/tagout, 1910.147
- Powered industrial trucks, 1910.178
- Ladders, 1926.1053
- Electrical wiring methods, 1910.305
- Machine guarding, 1910.212
- Electrical general requirements, 1910.303
In September 2016, OSHA credited TimkenSteel Corp. for improving its health and safety management system when it announced the company had been cited and penalized $113,131 for violations associated with a March 2016 fatality at a Canton, Ohio, steel mill. A nitrogen leak had caused an oxygen-deficient atmosphere in an elevator control room which the worker had entered to perform monthly fire extinguisher checks, causing his death, OSHA reported. The citation alleged that the company violated 1910.1200(h)(3)(i) in that the company’s training did not include methods or observations for detecting the presence or release of a hazardous chemical in the work area and had failed to ensure employees working with nitrogen to power pneumatic tools received training on the hazards, effects, and detection of nitrogen.
Howard Eberts, OSHA's area director in Cleveland, said the company discontinued the use of nitrogen to power tools and removed all the connections from the ventilation systems after the fatality occurred.
This article originally appeared in the November 2016 issue of Occupational Health & Safety.