OSHA: GHS Material Safety Data Sheet (SDS) Format for HAZCOM
OSHA GHS format background
The new OSHA GHS format evolved out of the need for a harmonized and unambiguous standard for safety information about hazardous products. In 1983, the Occupational Safety and Health Administration (OSHA), published the Hazard Communication Standard (HAZCOM). This important standard was often referred to as the employee right-to-know standard because it ensured that workers had access to information and training about hazards of chemicals and products they were exposed to at work.
The Revised OSHA HAZCOM Standard for MSDS
One of the main requirements of OSHA’s HAZCOM standard was for manufacturers and distributors of hazardous products to develop and make available Material Safety Data Sheets (MSDS) for their products. But while the OSHA standard mandated very specific health and safety information about the products be provided in the MSDS, HAZCOM was a performance based standard.
This meant that there was no specific format that had to be utilized by manufacturers and distributors for developing their MSDS, nor were there any standardized hazardous ratings or precautions. As a result, MSDS’ took all shapes and forms in part because manufacturers and distributors used different formats as they prepared the document.
This led to a lot of frustration among workers as they got confused while trying to interpret the documents. Because of this, OSHA revised their Hazard Communication (HAZCOM) standard and did away with the requirement for Material Safety Data Sheets (MSDS).
Now, manufacturers and distributors of chemicals and products will have to start providing a new information document called a Safety Data Sheet (SDS). While the information provided in the new Safety Data Sheets is very similar to that contained in the old MSDS’s, the information will now have to follow a specific order and format.
There is also a standardized hazard classification system that must be utilized on all SDS documents to convey information about the physical and health related hazards associated with the products.
The revised hazard communication (HAZCOM) program now requires employers to train their employees on how to read and understand the new GHS Safety Data Sheets (GHS SDS) format.
The HAZCOM standard consequently changed from employee-right-to-know to employee-right-to-understand.
OSHA GHS Safety Data Sheets (GHS SDS)
As part of the revision to the HAZCOM standard, OSHA adopted the GHS format for SDS’s. GHS stands for “Globally Harmonized System” of classification and labelling of chemicals. It is a standardized system which means that they will be consistency in the information appearing in Safety Data Sheets.
As the standard was developed by the United Nations, it means that once fully adopted and implemented, Safety Data Sheets for products around the world will be prepared in a standardized format. This is important for a global world economy which requires consistency in the presentation of information.
The SDS Format
In the new format all Safety Data Sheets will be broken down into 16 separate sections. These sections will have the same titles and will appear in the same order.
The information that must appear on OSHA GHS complaint Safety Data Sheets is as follows:
SECTION 1: Identification
This section of the SDS contains the following information:
- Product name as it appears on the product label
- Synonyms of the product
- Chemical classification codes
- Supplier information such as name of manufacturer or distributor, address and emergency contact number
- Supplemental information such as expiry dates
All of the information in the identification section must match that appearing in the container label.
SECTION 2: Hazard Identification
The information contained in the hazard identification section of the data sheets includes:
- GHS hazard classification for health and physical hazards
- Hazard categories
- Appropriate signal word associated with the product. There are two possible signal words under GHS: “Danger” which indicates a severe hazard, and “Warning”, which is less severe but potentially harmful
- Hazard Statements which give employees a quick warning of the kind of hazards associated with the product. Examples include- “toxic if swallowed” and “highly inflammable liquid”
- Precautionary Statements which present information on how to prevent or lessen exposure to the hazard
- Pictograms which are standardized icons that let workers quickly identify the types of hazards associated with the products. There are eight different pictograms for the health and safety hazards covered in the GHS system
- Information about unclassified hazards that are not covered in the GHS system such as combustible gas
SECTION 3: Composition/Information on Ingredients
This section identifies chemicals contained in the product. This could be a single ingredient (pure substance) or a number of ingredients if the chemical is a mixture. Other information contained in the section include:
- Common name or synonyms
- CAS Number (Chemical Abstraction Services Number)
- Composition by weight of the hazardous ingredients
- Any trade secret claim which indicates that the identity of the chemical has been withheld as a trade secret
SECTION 4: First Aid Measures
This are the initial first aid measures that should be administered by respondents to anyone who has experienced a chemical exposure. The section contains information on:
- List of first aid measures depending on the route of exposure be it contact, inhalation or ingestion
- Description of the symptoms of exposure, including those which are acute or delayed.
- Recommendations for medical care and special treatment that may be needed in severe cases
SECTION 5: Firefighting Measures
This provides the manufacturers’ recommendations for fighting fires involving their products. Here, you will find:
- Recommendations for suitable fire equipment for extinguishing the fire. Also, there will be information about extinguishers that are not appropriate
- Special hazards that may occur when the product is on fire
- Hazardous by-products generated during the combustion of the products
- Recommendations for special personal protective equipment (PPE) for firefighters
- Precautions to be utilized by firefighters
SECTION 7: Handling and Storage
The section contains information for the safe handling of products and chemicals to prevent or minimise the risk of release into the environment. Other information contained in the section includes:
- Prevention measures in case of exposure or contamination of personnel
- Recommended hygiene practices such as prohibition against smoking, drinking or eating in or near areas where products are stored
- Incompatibilities with other products or agents such as water or high temperatures which might cause the product to react
SECTION 8: Exposure controls/Personal Protection
This section lists the OSHA permissible exposure limits (PEL’s) for the chemicals contained in the product. These mandatory limits dictate when and where it will be necessary to utilize controls such as ventilation systems or respiratory protection devices.
These are necessary to protect workers from the ill effects of over-exposure to the chemicals
There may also be listings for the voluntary threshold limit values (TLV’s) established by the American Conference of Governmental Industrial hygienists (ACGIH) or similar limits established by similar groups.
The section will also list the appropriate engineering controls where applicable such as:
- Recommendations for exhaust ventilation systems
- Enclosures to contain emission
- Other recommendations for personal protective equipment (PPE) including any special requirements for providing special types of PPE such as respirators, googles or gloves
SECTION 9: Physical and Chemical Properties
While most workers may not care about this type of information, safety manager and engineers may have a need to know about specific information on the product. This information includes
- Smell, look, temperature, freezing and boiling points
- Flash point which is the temperature at which the product emits enough vapour to catch fire or cause an explosion
- Levels of vapour that will burn or cause an explosion
- Vapour density
- pH level for corrosive materials
SECTION 10: Stability and Reactivity
Information on any other materials that may be incompatible with the products as well as the conditions to avoid during storage or handling. These conditions include temperature extremes, shock and static discharge.
There will also be information on conditions that will cause the product to release excessive pressure or heat, or create decomposition by-products that could be harmful to expose workers.
Where applicable, the section may provide information on appropriate stabilizers that may be used to maintain stability of the product.
SECTION 11: Toxicological Information
This section lists the routes of exposure the chemical will use to get into the body system. This includes inhalation, ingestion and skin and eye contact. Also listed are the effects of over-exposure to the product such as:
- Acute and chronic effects
- Target organ effects
The measures of toxicity, for example LD/50 which is the estimated amount of a substance expected to kill half of the test animals in a single dose. If the chemical is an actual or potential carcinogen, that information will also be provided in this section.
Sections 12 through to 15 all deal with requirements regulated by other entities such as the Environmental Protection Agency (EPA) or the Department of Transportation. These sections are not regulated by OSHA but appear in the Safety Data Sheets so as to consistent with the GHS format:
- SECTION 12: Ecological Information
- SECTION 13: Disposal Considerations
- SECTION 14: Transportation Information
- SECTION 15: Regulatory Information
SECTION 16: Other Information
The section lists other information such as:
- Date and preparation of the data sheet
- Version information of data sheet- if it an original or revision
- Overview of any changes that were made during the last revision
- Any other information that the manufacturer or distributor deems fit to be included in the Safety Data Sheets
- Any other applicable disclaimer
Under the new HAZCOM standard, every employer has responsibilities that they have to fulfil. These responsibilities include but are not limited to:
- Gather new SDS for all the hazardous products and chemicals for which their employees are exposed to
- Make sure the SDS’s are readily accessible during each work shift to employees while they are in the work area
- Conduct training of workers regarding the new Safety Data Sheet format
These things must be done by the deadlines established by OSHA in their revised Hazard Communication (HAZCOM) standard. The OSHA deadlines, some of which have already lapsed, are:
- Publishing of the revised HAZCOM standard which was done on March 24th, 2012
- Suppliers must provide the new Safety Data Sheets not later than June 1st, 2015
- Training of staff on new SDS format must have begun by December 1st, 2013
- Employers must revise their written HAZCOM programs by June 1st , 2016 to reflect the new requirements