Q. With the new GHS rules, who has to create Safety Data Sheets and what kind of information must go into them?
A. Now that the Occupational Safety and Health Administration (OSHA) has adopted the Globally Harmonized System (GHS) into the Hazard Communication Standard, employers and chemical manufacturers must take several steps to ensure they remain in compliance with the new HazCom 2012. In this article, we will focus on Safety Data Sheets, or SDSs.
What Has NOT Changed with SDSs?
The HazCom Standard exists to ensure that employees know about and understand the hazards presented by the chemicals they work with. This has not changed. Chemical manufacturers are still required to label and document hazardous chemicals, and employers are still required to train employees in how to handle those chemicals safely. [29 CFR 1910.1200(b)(2)]
Employers are still required to keep a directory of Safety Data Sheets, so employees can look up safety and health information on a given chemical. However, employers only have to create these forms for chemicals they produce themselves. [29 CFR 1910.1200(g)(1)]
The primary burden on developing Safety Data Sheets falls on chemical manufacturers or importers. They are the ones required to develop SDSs for all hazardous chemical(s) they produce or import. These documents must be supplied to employers and distributors with the initial shipment of the chemical, and manufacturers must provide updated SDSs with the first shipment after an update. They must also provide the document upon request. This is all still true. [29 CFR 1910.1200(g)(7)(i)]
As an aside, if you do not plan on ordering a new shipment of a particular hazardous chemical any time soon, it is in your best interest to request an updated Safety Data Sheet.
What Has Changed?
The first, most obvious, difference is the name. These documents are no longer called Material Safety Data Sheets (MSDSs), but are now instead simply Safety Data Sheets (SDSs). This in itself is not a substantial change.
The information that goes into an SDS has also not changed that much. The big difference with the new SDSs is that now they must follow a particular format, while there was no mandatory format for the old MSDSs. As the new mandatory format is the same as the existing ANSI standard for Safety Data Sheets (ANSI Z400.1), this change may not affect you. If your SDSs were already formatted this way, you are already in compliance.
The new format—the required fields that must go onto an SDS, as well as the specific information that must be recorded in each field—is found at Appendix D to 1910.1200. The structure of an SDS consists of 16 fields. Twelve of these fields are mandatory and include information on the identity of the chemical, its composition/ingredients, first-aid measures, emergency response instructions, handling/storage guidelines, general chemical properties, etc. Four areas are non-mandatory, because they are beyond the scope of what OSHA is authorized to regulate. These include ecological information, transportation information, etc.
What Should an Employer Do?
As stated earlier, employers should be proactive about getting the updated SDSs from their suppliers. It’s also a good time to start using SDS sorting software, if you do not do so already, to manage the influx of new SDSs.
Keep in mind that some chemicals in your facility that were previously not regulated will now meet the revised definitions for hazardous chemicals. You will need brand new SDSs for these new hazardous chemicals and will need to work them into your overall HazCom plan.
You must comply with the revised HazCom standard, including the new style, by June 1, 2015. If new hazards are identified, all employers must update their workplace communication for those particular chemicals by June 1, 2016.