REFERENCE DATA SHEET ON
MATERIAL SAFETY DATA SHEETS
By:
Richard Gullickson, CIH
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The purpose of a Material Safety Data Sheet (MSDS) is to inform industrial purchasers and users of hazardous chemicals of the reasonably foreseeable physical and chemical hazards that may arise from the use of those chemicals. Most materials packaged for consumer use are exempt from the requirements of the Hazard Communication Standard (HCS). The MSDS should include precautions for normal use, handling, storage, disposal, and spill cleanup. It should not include recommendations for protective measures that are more strict than needed. OSHA states, in the inspection procedures for the HCS, 10 "Some MSDSs include recommendations for protective measures that are for 'worst case scenarios,' e.g., recommending supplied air suits for products of relatively low toxicity. The HCS requires that accurate information be provided on the MSDSs. This applies as much to 'overwarning' on the MSDS and label as well as the absence of information ('underwarning')."
HISTORY On November 25, 1983 OSHA published the Hazard Communication Standard as
29 CFR Part 1910, adding §1910.1200. This initial standard applied only
to Standard Industrial Classification (SIC) Codes 20 through 39.
The requirement that manufacturers and distributors provide MSDSs to their
customers became effective on November 25, 1985. The standard does not
require a particular format for the MSDS, but does specify what information
must be included. Effective September 23, 1987, the requirements of the
standard were extended to include "... all employers with employees
exposed to hazardous chemicals in their workplaces." In 1986 the U.S. Environmental Protection Agency (EPA) published the
"Emergency Planning and Community Right-To-Know Act of 1986,"
and in 1988 "Toxic Chemical Release Reporting: Community Right-To-Know."
The use and distribution of MSDSs is an important part of these regulations.
The "Toxic Chemical Release Reporting" regulation requires that
MSDSs for chemicals requiring reporting by these regulations contain specific
language notifying users that these chemicals are subject to these regulations.
These and other EPA regulations have been promulgated under Title III C
Emergency Planning and Community Right-To-Know Act of the Superfund Amendments
and Reauthorization Act of 1986 (EPCRA). OSHAs definition of a hazardous chemical is broad, and includes many
materials that might otherwise be considered innocuous. Because of the
potential for product liability suits, and the demands of customers for
MSDSs for almost all materials they purchase, manufacturers usually prepare
MSDSs for even relatively harmless materials. IMPLICATIONS: CONTENT OF A MATERIAL SAFETY DATA SHEET IMPLICATIONS: The quality and accuracy of MSDSs varies widely. One recent study
showed that of 150 randomly selected MSDSs, information was accurately
identified in Health Effects in 37%, in First Aid Procedures in 76%, in
Personal Protective Clothing in 47%, and in Occupational Exposure Limits
in 47%. 11 A Material Safety Data Sheet
is for the benefit of people who work with hazardous chemicals. If it is
not in a reasonably accurate, useful, and understandable format, it will
not achieve its purpose.
STANDARDIZATION OF MATERIAL SAFETY DATA SHEETS
In an effort to improve the completeness, accuracy, and consistency
of MSDSs, the Chemical Manufacturers Association (CMA) has developed a
voluntary standard for their preparation. The standard was published in
1993 as ANSI Z400.1-1993, "American National Standard for Hazardous
Industrial Chemicals -- Material Safety Data Sheets -- Preparation." 12
The Standard is 179 pages long. It establishes an MSDS format containing
sixteen sections. A very brief description of the purpose and scope of
each section follows. Section 1: Chemical Product and Company Identification Names
the material and relates the MSDS with the label and shipping documents.
Must also have a mailing address and telephone number for the manufacturer
or distributor. Section 2: Composition, Information on Ingredients Identifies
the hazardous components of the material. If non-hazardous ingredients
are listed, they should be listed separately. Chemical Abstract Service
(CAS) numbers should be included, as well as OSHA Permissible Exposure
Limits and American Conference of Government Industrial Hygienists (ACGIH)
TLVs. If the identity of any ingredient is claimed to be a trade secret,
it should be so indicated in this section.
Section 3: Hazards Identification Describes the material's appearance,
odor, and health, physical, and environmental hazards that may be of concern
for emergency response personnel.
Section 4: First Aid Measures This section should include emergency
and first aid procedures. It should be in layman's language, easy to understand,
and procedures for each potential route of exposure should be included.
A "Notes to Physicians" subsection should be included if such information
is available.
Section 5: Fire Fighting Measures This section should describe
fire and explosive properties of the material, extinguishing media to be
used, and fire-fighting instructions. It applies to anyone who may be in
the area of the fire. Section 6: Accidental Release Measures This section should have
information needed to prevent or minimize adverse effects on employees,
neighbors, property, and the environment, including waterways. It is intended
for emergency response personnel. Section 7: Handling and Storage This section provides guidelines
for minimizing any potential hazards from storing the material. It should
include information to minimize handling when appropriate, and conditions
such as temperature, inert atmosphere, and conditions to avoid. Section 8: Exposure Controls, Personal Protection Discusses
the degree of engineering control that may be needed when handling the
material, and the personal protective equipment that should be used if
there is a potential for exposure above the regulatory or suggested limits.
Exposure guidelines, such as OSHA PELs and ACGIH TLVs should be included
in this section. Section 9: Physical and Chemical Properties These properties
should be included to assist users to determine proper handling and storage.
Appearance, odor, physical state (liquid, solid, gas), pH, vapor pressure
and density, melting and freezing point, solubility, and specific gravity
should be included. Additional properties may be included if they are useful. Section 10: Stability and Reactivity This section should describe
conditions that may result in a potentially hazardous reaction, such as
evolution of hazardous gases, production of heat, or other hazardous conditions.
Section 11: Toxicological Information This section should include
any known information resulting from animal testing or human experience
on the toxicity of the material. Also included would be information on
its potential for causing cancer. Data should be included for acute, subchronic,
and chronic exposures, if available. Section 12: Ecological Information This section should list
impacts to the environment that may occur if the material is released to
the environment, or in evaluating waste treatment practices. Section 13: Disposal Considerations This section is intended
to provide guidance to environmental and other technical people responsible
for waste management for the product. Section 14: Transport Information This section should provide
information concerning classification for shipping the material. It should
include U.S. Department of Transportation (DOT) classifications, or an
indication that it is not regulated. It may include information for shipment
into other countries. Section 15: Regulatory Information This section should contain
information regarding the regulatory status of the material. It should
include OSHA AND EPA regulations. It may also include other regulatory
agencies, and state agencies, if appropriate. Section 16: Other Information This section is intended for other
material the preparer feels is pertinent, and that should not be included
in the other fifteen sections. For example, it may include label information,
hazard ratings, revision dates, and references to other related information. IMPLICATIONS: REFERENCES
In the 1940s the Manufacturing Chemists' Association, now known as the
Chemical Manufacturers Association (CMA), began producing "Chemical
Safety Data Sheets" containing "Properties and Essential Information
for Safe Handling and Use" of some of the more important hazardous
chemicals used in commerce. Ultimately about 100 of these Data Sheets were
produced. They were very detailed in their coverage of each chemical, to
the point of being almost a stand-alone book on the product. The longest
Data Sheet was 46 pages. Later, some chemical companies began to produce
data sheets for some of their high volume or hazardous chemicals. CMA no
longer produces or supports the "Chemical Safety Data Sheets."
OSHA requires manufacturers and importers of hazardous chemicals
to distribute Material Safety Data Sheets with information concerning reasonably
foreseeable health and toxicity concerns arising from their use. Users
of these chemicals are required to ensure that these MSDSs are received
with chemicals they purchase, and that they are used and available in the
workplace.
Paragraph (g) of the OSHA Hazard Communication Standard specifies what
must be contained in MSDSs. OSHA publishes a form that can be used for
the MSDS, but does not require its use, as long as all of the required
information is included. A condensed version of the language in the standard
follows. Chemical manufacturers and importers shall obtain or develop a
Material Safety Data Sheet for each hazardous chemical they produce or
import. Employers shall have a Material Safety Data Sheet in the workplace
for each hazardous chemical they use.
OSHA requires an extensive amount of specific information to be included,
but the MSDS should not be a complete scientific work on the hazardous
chemical. Employers may accept the content of an MSDS from a supplier unless
they know it is incorrect. However, the employer must ensure that an MSDS
is available for each hazardous chemical, and that it contains all of the
required information. If an MSDS is not received, the employer must contact
the supplier to request one. If the information is still not received,
OSHA should be contacted for assistance.
Since the OSHA Hazard Communication Standard does not impose a format
on MSDSs, there is a wide variation in the order in which the information
is presented, and in the number of pages. The length of an MSDS can range
from two pages to eight pages or even more. Some companies, in order to
make the MSDS more uniform for their training programs, have transferred
the information on vendor MSDSs into their own uniform format. The hazard
of handling the information in this way is that the company then becomes
the "responsible party" for the content of the MSDS.
Although the OSHA Hazard Communication does not require the use of
a specific format for the preparation of MSDSs, many suppliers may request
them in the ANSI format in the interest of having a more uniform placement
of information. This may aid them in training their people to use these
chemicals and materials safely.
This is a Reference Data Sheet that has been compiled from a number
of sources, and is intended to be a concise, relatively non-technical source
of information on a particular subject. It is provided in good faith and
is believed to be correct as of the date compiled; however, Meridian Engineering & Technology,
Inc. makes no representation as to the comprehensiveness or accuracy of the information.
It is expected that individuals receiving the information will exercise their independent
judgment in determining its appropriateness for a particular purpose. Accordingly,
Meridian Engineering & Technology will not be responsible for damages of any kind resulting
from the use of or reliance upon such information.