The Occupational Safety and Health Administration’s (OSHA) Globally Harmonized System of Classification and Labelling of Chemicals (GHS) revisions to the hazard communication standard (HazCom) have been in effect since May 2012, including a 3-year phase-in period that manufacturers, importers, and distributors will have to switch the material safety data sheets (MSDSs) to the new safety data sheets (SDSs) format.
Many employers are now facing a two-part conundrum concerning the ongoing transition from MSDSs to SDSs in their workplaces:
- How to manage the data sheet filing and employee access system when there are both MSDSs and SDSs for workplace chemicals; and
- How to train employees to understand both the new SDS and the old MSDSs during the transition.
Because HazCom 1994 did not establish a uniform format, there are currently a number of different MSDS styles and formats in use in the United States. HazCom 2012, on the other hand, mandates the use of a universal GHS format for the SDS, a format that is a strict 16 sections. In short, the format is being standardized for ease of training and notification of hazards.
However, during the 3-year phase-in period to HazCom 2012, you should expect your MSDS library to have a mix of non-GHS formatted—or MSDSs—and the GHS-formatted SDSs until the phase-in is complete when the chemical manufacturers, distributors, and importers have reclassified all of their chemicals using the GHS criteria. Many of these entities will be making the shift to the GHS-compliant SDSs in stages—they have until June 1, 2015 (distributors have until December 1, 2015).
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The first HazCom 2012 deadline was December 1, 2013, when more than 5 million U.S. workplaces should have trained their employees on the new label elements and the SDS format. This may be confusing for a while because for the next 30 months, some workplaces may not even see a GHS-compliant SDS.
Managing the MSDS and SDS
1. Develop a plan. What OSHA expects is that you have a plan in place to ensure that as updated SDSs come into your organization, they are handled properly. This means having a management system in place comparing the new SDSs to the old ones to see if there are any new hazards that employees need to be trained on to understand what they are working with and ensuring the updated documents are made available to employees in a timely fashion. Now HazCom 2012 is not only the right-to-know rule but also the right for your employees to understand the hazardous chemicals with which they work and how to safely handle them. There is no requirement to keep the old MSDSs once you receive an updated SDS to replace it. But keeping an electronic archive is a good idea. An electronic system can also simplify the transition.
2. Perform an inventory of the chemicals in your workplace. This will not only save you time in updating for chemicals no longer present, but will ensure you have up-to-date MSDSs/SDSs for all the chemicals in your workplace to which your employees are exposed. The latest SDS for each hazardous chemical must be made available in the workplace; all your employees must be able to access SDSs at all times. This means a supervisor’s permission is not required, and the SDS access management system is always functional.
The chemical manufacturer, importer, or employer preparing the SDS is responsible for the accuracy of the information provided on their SDSs. The preparer must ensure that the information provided accurately reflects the scientific evidence used in making the hazard classification. Employers that rely on SDSs supplied by a manufacturer, importer, or distributor are not liable for their accuracy as long as they have accepted the SDS in “good faith,” that is, without blank spaces or obvious inaccuracies. You should report inaccurate or missing information on an SDS to the chemical manufacturer or distributor.
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For employers that do their own evaluation or classification of a chemical, OSHA will hold them responsible for the accuracy of the SDS.
In tomorrow’s Advisor, we’ll look at training on data sheets—plus we’ll explore a fast-paced, online training resource of ready-to-use courses on dozens of key safety topics.