As of June 1, 2015, material safety data sheets will be no more!
But they aren’t quite disappearing entirely. They’re undergoing a name change and a major revamping. They’ll be called Safety Data Sheets instead. Chemical labels will change, too.
The reason for the change: on March 26, OSHA will be publishing changes to the Federal Hazard Communication Standard, so it conforms to the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
Multinational corporations have pushed for this, so they don’t have to create one data sheet for each country in which they do business. But adopting GHS has a huge benefit for users: it is an attempt to standardize the information on chemical labels and SDSs. That standardization means we’re less likely to see one product labeled as “danger: corrosive” and another product, identical in composition and strength, labeled as “caution: irritating.”
Companies that use OSHA’s Form 174 for data sheets will have to make major changes. But many manufacturers have switched to a voluntary ANSI standard for a 16-part data sheet. That format will now be required. (There are parts of that form, such as transport or disposal information, that aren’t under OSHA’s jurisdiction, so OSHA won’t enforce those). Those companies will have to redo their SDSs, to conform to the GHS classifications. But the look of the data sheets won’t change much.
Data sheets won’t become shorter. They may become easier to understand, though, with the information that workers need most placed at the front of the SDS.
Labels will have major changes:
- You’ll see pictograms used to indicate the type of hazard. Most of these are easy to understand and familiar to anyone who’s seen DOT placards. There are a few new ones, such as a starburst torso, for serious chronic hazards.
- Labels will need to include signal words (“warning” or “danger.” “Caution” will no longer be used), hazard statements, and precautionary statements. The language to be used is spelled out in the GHS standard – it isn’t up to the label writer.
The standard changes some important definitions. A flammable liquid used to be one with a flashpoint under 100°F. Now, it’s one with a flashpoint below 200°F (or, to be precise, 199.4°F). To be consistent, that means that OSHA’s standards on flammable and combustible liquids (including those for spray finishing and coating/dipping operations) have to change. There are no changes in what employers have to do, just a change in definition. Liquids with flash points between 140°F and 200°F had been called combustible. Now they’re Category 4 flammable liquids. Slightly confusing for now, but not a substantive change. In fact, this change results in greater consistency with DOT regulations.
People who commented on the proposed standard raised a concern about one potential source of confusion. The NFPA diamond (NFPA 704) and the Paint and Coatings Manufacturers’ HMIS system code chemical hazards from 0 (no hazard) to 4 (most serious hazard). GHS uses the opposite scale. A Category 4 flammable liquid is much less flammable than a Category 1 flammable. As the HMIS and NFPA 704 systems use shapes and colors to convey the type of hazard, we doubt this will create problems.
This new standard creates a lot of immediate work for chemical manufacturers and distributors, as they’ll have to update their labels and SDSs. For end users – it really shouldn’t be a headache.
The two things end users need to do:
- Update their safety data sheets. Keep in mind, though, that electronic access is allowed, as long as employees have ready access. We’ve been favoring electronic access to data sheets well before this, to minimize the paperwork shuffle from trying to maintain hard copies of MSDSs.
- Train employees on understanding the new labels and SDSs
Minnesota has its own version of the Hazard Communication Standard, called the Right to Know law. The state has six months to adopt the changes or to make its own changes, to ensure the state program is at least as strong as the federal requirements. We expect that the state will modify its rules to require the GHS-compliant labels and safety data sheets, but don’t expect any other major changes to Right to Know requirements.
Keep in mind that these dates may be delayed in Minnesota.
- Now: chemical manufacturers and employers can comply with either the old MSDS and labeling requirement or the new SDS and labels.
- December 1, 2013: Employees need to be trained on the new SDS format and labels. Of most importance, that means training them on understanding the pictograms. That’s not a huge deal.
- June 1, 2015: All of the new data sheets should be out. Material safety data sheets are obsolete.
- December 1, 2015: All product labels should be updated.
- June 1, 2016: Any alternative labels used in a workplace need to be updated. If new hazards are identified when a product is reclassified according to GHS, the employer needs to train employees on that new hazard.