A Safety Data Sheet’s 16 sections contain important, even lifesaving, information on chemicals used in the workplace. Yet employers and workers can get tripped up when trying to comprehend the details.
“It’s important to train workers on how to properly read – and especially understand – the SDS,” said Atanu Das, owner of SDSWriter, an authoring and consulting firm in Skokie, Illinois. “It’s essential for a compliant hazard communication program.”
Added Frankie Wood-Black, division chair of engineering, physical science and process technology at Northern Oklahoma College: “The best way to do training is to explain the ‘why’ behind it.
“Not everybody needs to know all 16 sections. What’s the important information that somebody has to utilize?”
From the ‘Wild West’ to today
In 2012, OSHA revised its standard on hazard communication (1910.1200) to include the requirement that SDSs follow the current 16-section format. That includes three sections consistent with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals.
The update has created a more standardized and easily digestible SDS format.
“Before that time, it was basically the Wild West of formats,” said Das, who is a fellow of the Institute of Hazardous Materials Management. “We saw a big plethora of craziness when it came to SDSs and how good they were at conveying the knowledge that we needed them to.”
For example, workers now can quickly locate information on the physical and health hazards associated with a chemical in Section 2 of its corresponding SDS.
What are the whys?
When Richard Flynt, a senior safety consultant at the National Safety Council, educates workers on SDSs, his focus is twofold: “No. 1, how to get them. No. 2, what it is you might need to know.”
Wood-Black, who teaches the importance of SDSs to first-year college students planning careers in processing roles, said workers can understand the whys of an SDS based on their job description.
“The person in the warehouse needs to know storage and handling instructions,” she said. “The person pouring the chemical into the batch or utilizing the chemical needs to have a different set of instructions. They also need to know: ‘Why are we using this glove? Why are we wearing splash protection? Why are we using spill protection?’”
Ensure access
Flynt says one of the biggest issues facing employers is how workers find and access SDSs. He learned this lesson years ago.
“I’ve had OSHA come to a site that I was at, walk right out to a worker and say, ‘I want you to pretend that you just got some of this in your eye. Show me where you would get information about that chemical,’” he recalled. “And that worker was unable to do it. That was a big education for me.” After that visit, Flynt said he trained every worker on how to quickly and easily locate SDSs.
Because OSHA requires the resource to be readily accessible during each work shift, Flynt recommends “a computer dedicated to SDSs out on the work floor” that isn’t protected with a password. To ensure access to SDSs during power outages, he says, some employers set up computers with uninterruptible power supplies. He adds, however, that old-fashioned paper binders can be placed wherever workers are during a shift. Binders also allow an individual printout of an SDS to travel with a worker in the event of an emergency trip to an ER or other medical facility.
“When they get to the hospital,” Flynt said, “the emergency room doctor can say, ‘I know exactly what the pH of this is. I know exactly what it’s doing to the worker’s eyes. I know how to counteract that.’ It helps tremendously.”
Other common issues
The challenges of SDSs don’t stop with accessibility. Other things to be aware of:
Outdated versions: After a chemical manufacturer or employer becomes aware of significant new information concerning the hazards of a chemical, OSHA requires that the corresponding SDS be revised within three months to prevent risks.
The process of ensuring workers have the most up-to-date information at their fingertips can be time-consuming. When Flynt was a corporate safety manager for a large automotive company that did work in Canada, he learned that Canadian SDSs expired every three years and each SDS came with a different expiration date.
“It’s been a stone in my shoe everywhere I’ve gone,” he said. “They’re challenging because they’re a huge time suck.”
Language barriers: “One thing we’re seeing is a lot of employers may ignore the worker language barriers that an employee may have,” Das said. “Workers may not be speaking English as their primary language. OSHA does require you to provide SDSs and other hazard communication translated into the primary language of the worker.”
Quantity and type of use: How much of a chemical and what its use is are both important questions to answer when determining whether you need an SDS.
“If a secretary has a bottle of hand sanitizer on her desk, that’s a consumer product being used in consumer quantity,” Flynt said. “If you’re going to buy it in 55-gallon drums and dispense it in 1-gallon pumps all over your facility because it’s part of your process to sanitize your hands, that’s not a consumer product being used in a consumer quantity.”
The same goes for common spray cans of lubricants, degreasers and rust protectants in a maintenance shop.
Das says finding answers to these and other questions – “if this is a hard problem to crack” for your organization – is as simple as a phone call to OSHA.
What’s in a safety data sheet?
Under the OSHA standard on hazard communication (1910.1200), safety data sheets are required “to be presented in a consistent user-friendly, 16-section format.” Here’s the information the agency says each section must contain.
Section 1: Identification. Includes identity of the chemical, its recommended uses and any restrictions of use.
Section 2: Hazard(s) identification. Contains hazard classification, signal word and appropriate pictograms.
Section 3: Composition/information on ingredients. Lists product ingredients, mixtures and chemicals where a trade secret is claimed.
Section 4: First aid measures. Describes initial care to be given to an individual who’s been exposed.
Section 5: Firefighting measures. Recommendations for fighting a fire caused by the chemical.
Section 6: Accidental release measures. Provides appropriate response to spills, leaks or releases, including containment and cleanup practices.
Section 7: Handling and storage. Guidance on safe handling practices and conditions for safe storage.
Section 8: Exposure controls/personal protection. Indicates exposure limits, engineering controls and personal protective equipment measures to minimize exposure.
Section 9: Physical and chemical properties. Includes details about the chemical, such as appearance, odor, pH, flash point, flammability, etc.
Section 10: Stability and reactivity. Describes the chemical’s hazards in three sections – reactivity, chemical stability and other.
Section 11: Toxicological information. Features delayed, immediate or chronic effects from short- and long-term exposure.
Section 12: Ecological information (nonmandatory). Includes information to evaluate the environmental impact of the chemical were it to be released.
Section 13: Disposal considerations (nonmandatory). Proper disposal practices, recycling or reclamation of the chemical and its container.
Section 14: Transport information (nonmandatory). Guidance for shipping and transporting the chemical by road, air, rail or sea.
Section 15: Regulatory information (nonmandatory). Lists safety, health and environmental regulations for the product not indicated elsewhere on the SDS.
Section 16: Other information. Details on when the SDS was prepared and its last known revision.