Train Employees on Safety Data Sheets (SDSs)

Along with labels on containers and SDSs, employee training is one of the three core components of a comprehensive hazard communication program. Remember that under HazCom 2012, your employees not only have the right-to-know but also the right to understand the chemicals in the workplace and how to handle them safely.

Training is needed to explain and reinforce the information presented in the SDSs to ensure that your employees understand the chemical hazards in their workplace and are aware of the protective measures they need to follow. Creating an effective HazCom 2012 training program may actually be easier than before because of the standardized format of the SDS that may improve hazard communication overall.

As part of the training, your employees must understand the standardized headings and sequence of information on SDSs. Although written information is important, training is an opportunity to explain the information on the SDS and helps to ensure that the messages are being received accurately.

To ensure employee understanding is effective, train on MSDS and SDS formats as long as you have MSDSs. Keep in mind that because there is a 30-month transition period, if you have MSDSs in your workplace, you must include training on those MSDSs in your training program. We are not aware of any statement from OSHA to stop training employees to interpret the old MSDSs if they are still used in the workplace. Nevertheless, your employees need to know the SDS universal format.

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Although the transition may seem overwhelming at first, creating and following a plan for your GHS transition will make the process more successful.

The new SDS

When the SDSs begin to show up at your workplace, they will all follow this universal 16-section format that should make it easier for you to better know the physical and health hazards of the chemicals used in your workplace; to understand safety practices; and to train your employees.

The 16 sections in an SDS are required in the following order with the following headlines:

1. Section 1: Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
2. Section 2: Hazard(s) identification includes all hazards regarding the chemical; required label elements.
3. Section 3: Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
4. Section 4: First-aid measures includes important symptoms/effects, acute, delayed; required treatment.
5. Section 5: Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
6. Section 6: Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
7. Section 7: Handling and storage lists precautions for safe handling and storage, including incompatibilities.
8. Section 8: Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
9. Section 9: Physical and chemical properties lists the chemical’s characteristics.
10. Section 10: Stability and reactivity lists chemical stability and possibility of hazardous reactions.
11. Section 11: Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
12. Section 12: Ecological information*
13. Section 13: Disposal considerations*
14. Section 14: Transport information*
15. Section 15: Regulatory information*
16. Section 16: Other information includes the date of preparation or last revision and any other pertinent information.

*Note: Since other agencies regulate this information, OSHA will not be enforcing Sections 12 through 15 (29 CFR 1910.1200(g)(2)).

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Train for Compliance—and for Safety’s Sake

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