Safety Tidbit 3.42 - When is an SDS just an MSDS

Safety Tidbit 3.42 – When is an SDS just an MSDS

Reference:       OSHA Hazard Communication Standard

A bit of a short tidbit this week. I was reviewing an employer’s hazard communication program. When I asked, the client said they had SDSs for all their chemicals in the shop. However, when thumbing through the book I noticed some had the heading Material Safety Data Sheet (MSDS).
 

Upon closer inspection, the MSDS sheets were in the sixteen-part format but were missing key parts of the hazard identification section: namely the signal word and hazard statements. OSHA’s 2012 Hazard Communication standard requires “chemical manufacturers and importers to evaluate chemicals produced in their workplaces or imported by them to classify the chemicals. For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and, where appropriate, the category of each class that apply to the chemical being classified. [1910.1200(d)(1)]” Furthermore, chemical manufacturers, importers or employers classifying chemicals shall identify and consider the full range of available scientific literature and other evidence concerning the potential hazards. [1910.1200(d)(2)] Ultimately, employers are not required to classify chemicals unless they choose not to rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this requirement.

The employer labeled the containers according to the “MSDS.” Unfortunately, when we looked on the manufacturer’s website they had updated the chemical’s Safety Data Sheet with all the correct information.

Bottomline, don’t take on more responsibility than necessary. If the manufacturer labels the data sheet as a Material Safety Data Sheet, then that’s what it is. It is not a Safety Data Sheet as it has not gone through the rigor to include all the information the new hazard communication standard requires the manufacturer to include.

Hope this was helpful and thank you for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.