Safety Data Sheets, GHS Compliance, and the Realm of Hazard Communication

Posted: January 25, 2019 News

Any company that produces or uses chemicals in the workplace is required to ensure the health and safety of workers.  While the laws or regulations governing occupational health and safety may differ across nations, the premise is the same: hazard communication!  Hazard communication is how workers receive information about the hazards in their workplace and how they can and should protect themselves.  With respect to hazard communication of chemicals, this is achieved by safety data sheets (SDSs) and labels.  Employers with hazardous chemicals in their workplace typically are required to provide SDSs and labels that are accessible and understandable by workers.  After more than a decade-long effort by the United Nations, we now have an internationally agreed-upon system called the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) to guide us. Several countries have already adopted the GHS, including, but not limited to, the United States, Canada, Europe, and China.

Intrinsik has received numerous inquiries regarding SDSs over the years; these are the top ten frequently asked questions about safety data sheets!

  1. What is a Safety Data Sheet?

A safety data sheet (SDS), formerly known as a material safety data sheet (MSDS), is a document containing information on the health, physical, and environmental hazards of a chemical or a product.  SDSs inform employees of the potential adverse effects of hazardous chemicals/products in the workplace and how to handle and work with these chemicals/products in a safe manner.

2.  When are SDSs required?

SDSs are required for final products sold and distributed in commerce as well as intermediate chemicals/products internally used at a facility provided that the product contains one or more hazardous ingredients at 0.1% or higher in the formulation.  Typically, the safety regulation governing SDSs does not require SDSs for non-hazardous products, although this may differ by jurisdiction or country.  A manufacturer/supplier may opt to provide a SDS for non-hazardous products with shipment.  In the United States, employers are not required to maintain SDSs for non-hazardous chemicals as per the Hazard Communication Standard (HCS).

 3. What is the Globally Harmonized System?

Historically, MSDSs had multiple formats with information that varied across companies and jurisdictions.  However, beginning in 1992, the United Nations developed the GHS system/standard to define the format and content of SDS sand labels.  The GHS was designed to replace the various classification and labelling standards used in different countries with a unified, consistent approach on an international level.  The goal of the GHS is to establish the same set of rules for chemical hazard classification and communication via SDSs and labels among countries engaged in the global trade of chemicals.  The GHS standard may be adopted to cover chemicals in the workplace, transport, consumer products, pesticides, and pharmaceuticals.

4. What is the difference between a MSDS and SDS?

The main difference between a MSDS and SDS is that SDSs are based on a standardized 16-heading format that is intended to communicate the hazards of a product to employees in a more simple and effective manner.  A 16-section SDS includes the following headings in the order specified: 1) Identification; 2) Hazard(s) Identification; 3) Composition/Information on Ingredients; 4) First-aid Measures; 5) Fire-fighting Measures; 6) Accidental Release Measures; 7) Handling and Storage; 8) Exposure Control/Personal Protection; 9) Physical and Chemical Properties; 10) Stability and Reactivity; 11) Toxicological Information; 12) Ecological Information; 13) Disposal Considerations; 14) Transport Information; 15) Regulatory Information; and 16) Other Information.

5. Can you convert a MSDS into a SDS?

A MSDS can be converted into a GHS-compliant SDS.  The manufacturer/supplier should reference the jurisdiction’s regulation and guidance on the preparation of SDSs in order to convert a MSDS into an SDS.  The manufacturer/supplier may also consult an SDS authoring service (such as Intrinsik) to ensure compliance with the jurisdiction’s SDS requirements. 

6. Who is responsible for preparing, distributing, and updating a SDS?

A SDS is prepared by the manufacturer/supplier of the product, and it is distributed by the manufacturer/supplier with the initial shipment of the product and with the first shipment after a safety data sheet has been revised.  The manufacturer/supplier may need to update the SDS when regulations change, new scientific evidence or significant information emerges, or chemicals that were no longer in use are reintroduced into the workplace. 

7. Why do some SDSs look different than others?

SDSs may look different than others because the document style is chosen by the manufacturer/supplier.  While GHS-compliant SDSs follow the same 16-section format and order, the information can be presented differently.  Some manufacturers/suppliers also opt to provide supplemental information which may explain why some SDSs appear different than others. 

8. Do SDSs need to be translated into other languages?

A SDS must be in the official language(s) where the product is being placed on the market.  In the United States for example, the HCS states the SDS must be provided in a language employees can understand.  Therefore, the SDS can be provided in a language other than English to accommodate multiple languages spoken in the workplace.  In Canada, information provided on a SDS and label must be in both official languages: English and French.  The SDS may be provided as one bilingual SDS or as two separate SDSs (one each in English and French); if separate, both the English and French SDSs must be provided to the purchaser to be compliant with Canada’s Workplace Hazardous Materials Information System (WHMIS) requirements. 

9. Can one SDS be used for more than one country of destination?

The manufacturer/supplier or company providing SDS authoring services can author a single SDS if the product is being marketed in countries where the GHS has been adopted.  The single SDS would be GHS-compliant and prepared in accordance with each country’s SDS regulation.  Depending on the countries of destination, the SDS would address country-specific requirements or regulations as applicable and would be provided in the country-specific official language(s).

10. What if the product formulation is proprietary?

The manufacturer/supplier may choose to provide for protection of confidential business information (CBI).  When proprietary information has been withheld, the SDS or label must indicate this.  Specifically, a CBI claim pertains to the names of substances and their concentrations in the product.  All other information should be disclosed on the SDS and/or label as required, and any CBI should be disclosed to the competent authority upon request.  The competent authority must protect the confidentiality of the information in accordance with applicable laws and practice. 

Bonus Question: Do all countries use the GHS?

The United Nations monitors the status of GHS implementation in 72 countries: https://www.unece.org/trans/danger/publi/ghs/implementation_e.html#c25745.  Several regions/countries have fully implemented the GHS including, but not limited to, the European Union/European Economic Area, the United States, Canada, Switzerland, Turkey, Australia, Canada, Mexico, Argentina, Brazil, China, Republic of Korea, Japan, Singapore, Indonesia, Malaysia, Thailand, Vietnam, and New Zealand.  Additionally, other countries are in transitional periods, or have yet to initiate the GHS process.

Intrinsik Corp. Blogger: Alyssa J. Beltran, Intrinsik Ltd., Venice Beach, California

For more information on how Intrinsik can help your company author GHS-compliant SDSs, please contact Mr. Elliot Sigal, Vice President and Senior Toxicologist at 1-905-364-7800 or moc.k1550964667isnir1550964667tni@l1550964667agise1550964667 or Ms. Alyssa Beltran, Environmental Health Scientist at 1-310-392-6462 or moc.k1550964667isnir1550964667tni@n1550964667artle1550964667ba1550964667

References

Health Canada. 2015. Workplace Hazardous Materials Information System (WHMIS).

United Nations. 2017. Globally Harmonized System of Classification and Labelling of Chemicals (GHS), Seventh Revised Edition. ST/SG/AC.10/30/Rev.7.

United States Occupational Safety and Health Administration (OSHA). 2012. Hazard Communication Standard, 29 CFR 1910.1200.