Managing Material Safety Data Sheets
The material safety data sheet, or MSDS, is the primary tool for finding hazard and safety information about the chemicals used in your workplace. The MSDS lists the hazardous ingredients of a product, its physical and chemical characteristics, its effect on human health, chemicals with which it can adversely react, handling precautions, the types of measures that can be used to control exposure, emergency and first aid procedures, and methods to contain a spill.
OSHA requires that the MSDS be written in English. However, this should not prevent an employer with employees who speak English as a second language from providing data sheets in other languages. MSDSs must be readily accessible to employees with exposure risks during each work shift. If employees travel between work locations, MSDSs may be kept at a central location, as long as they are accessible.
Your involvement with MSDSs will depend on what category your company falls into. If you produce hazardous chemicals, your company is responsible for developing and sending out data sheets for each toxic substance produced. If your company only uses the chemicals, you are responsible for ensuring that there is an MSDS for each toxic substance that enters your workplace.
OSHA requires chemical manufacturers and importers to obtain or develop a material safety data sheet for each hazardous chemical they produce or import. The MSDS must either accompany the shipped containers or be sent to the employer prior to or at the time of the shipment, and with the first shipment after a data sheet has be revised. When new information about the safety or hazards of a chemical is learned, the manufacturer has three months to revise the MSDS.
Distributors are responsible for ensuring that their customers receive an MSDS for each chemical they purchase. Retail distributors that sell chemicals to commercial customers have to post a sign notifying customers that MSDSs are available and providing data sheets upon request.
If, under normal conditions of use, employees do not open sealed containers of hazardous chemicals, such as in warehousing or retail sales, the distributor need only maintain the MSDSs that are sent with incoming shipments. If an employee requests an MSDS and it is not available, the distributor must contact the manufacturer and request one. The primary difference is that the warehouse or hardware store does not have to maintain a complete file of data sheets. This simplifies the paperwork for operations where hundreds of different chemicals pass through, but are never opened or worked with.
Employers that use toxic chemicals in their operations and processes must have an MSDS for every hazardous chemical in their facility. Copies of these MSDSs must be readily available to employees.
The role of an MSDS is to provide detailed information on each hazardous chemical, including its potential hazardous effects, its physical and chemical characteristics, and recommendations for appropriate protective measures. This information is useful to you as the employer responsible for designing protective programs, as well as to your employees.
Although OSHA requires that the MSDS contain specific information, it does not specify a certain format. OSHA recommends that chemical manufacturers and importers use the American National Standards Institute ANSI Z400.1-1993 industry consensus standard for the preparation of material safety data sheets.
You (the employer), as the end user, are entitled to receive an MSDS for each chemical product you purchase. If you do not receive one automatically, you should request one. If you receive one that is obviously inadequate, with, for example, blank spaces that are not completed, you will need to request an appropriately completed one. If your request for a data sheet or for a corrected data sheet goes unanswered within a reasonable amount of time (OSHA suggests 30 days), you should contact your local OSHA area office for assistance in obtaining the MSDS. If you are still unable to get the data sheet, consider purchasing from another vendor.
Information that OSHA requires on every MSDS includes:
§ The identity used on the label (the chemical and common names);
§ If the substance is a mixture, all ingredients which are health hazards and in a concentration of 1 percent or more; for carcinogens, the concentration must be 0.1 percent or more;
§ Physical and chemical characteristics of the hazardous chemical (such as vapor pressure or flash points);
§ The physical hazards of the chemical;
§ The health hazards of the chemical;
§ The primary routes of entry;
§ The OSHA permissible exposure level, ACGIH TLV, and any other exposure limit used or recommended by the manufacturer;
§ Whether the chemical is a carcinogen (listed in the NTP, or the IARC, or by OSHA);
§ Precautions for safe handling and use;
§ Recommended engineering controls;
§ Emergency/first aid procedures;
§ Date of preparation; and
§ Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party who can provide additional information on the hazardous chemical and appropriate emergency procedures.
If you are not familiar with material safety data sheets and with chemical terminology, you may want to learn how to use them. A sample MSDS is located on pages 20-23 and a glossary of terms used in hazard communication may be found on page 28. Generally speaking, most employers using hazardous chemicals will primarily be concerned with MSDS information regarding hazardous effects and recommended protective measures. Focus on the sections of the MSDS that are applicable to your situation.
MSDSs must be readily accessible to employees when they are in their work areas. This can be accomplished in many different ways. You will need to decide what is the best format and storage method for your particular workplace.
For example, MSDSs can be paper, electronic data, faxed materials, CD ROM, or available from MSDS services. You can even find MSDSs on the Internet. Because there is no mandatory format that must be used, data sheets are available in a wide variety of formats.
OSHA does not have a specific requirement for storing MSDSs. You can choose the best method for your company. Remember, when choosing a format or a storage method, the MSDS must be readily available to employees no matter what shift they work.
§ Keep MSDSs in a binder in a central location, such as on a desk, bookshelf, or in a wall unit; or
§ Computerize the information and provide access through terminals.
For computerized data sheets, the employees or key employees have to know how to retrieve the data sheets. This may include training in basic computer skills as well as the software program used for the MSDSs. When employees don’t understand how to use the equipment, the MSDS is considered “not readily available.”
Finally, you must ensure the availability of the MSDSs in an emergency, such as power outage, fire, spill, or even electronic data equipment failure.
Electronic management of MSDSs can be a time, space, and paper saver, but you need to consider the drawbacks to it. Extra personnel training may be required in order for your employees to have ready access to the MSDSs. Also, if the electronic equipment is down, provisions will need to be made for a backup system. Nevertheless, MSDSs can be effectively managed electronically without affecting their availability to workers by careful review of the software, services, and other electronic equipment and by having an MSDS managing system backup.
If you have an off-site MSDS service that manages your data sheets, remember that all shifts must have MSDSs readily available. This means that employees must be able to contact the service and receive a faxed or hard copy of the requested MSDS during their work period. If they cannot, you may have to maintain copies at your facility.
If there is more than one distinct work area or location where hazardous chemicals are present, separate your MSDSs by area. Keep a master book with all data sheets in it, and then have departmental books with MSDSs for only the chemicals used in that operation. In the event of an emergency, employees won’t have to dig through masses of extra sheets to find what they need.
As long as employees can get the information when they need it, any approach may be used. The employees must have access to the MSDSs themselves — simply having a system where the information can be read to them over the phone is only permitted under the mobile worksite provision at §1910.1200(g)(9), when employees must travel between workplaces during a shift. In this situation, they have access to the MSDSs prior to leaving the primary worksite and when they return, so the telephone system is simply an emergency arrangement.
Toxic air emissions may be a by-product of a process or procedure in your facility. Areas that often get overlooked involve potentially toxic chemicals produced from welding operations, gasoline-powered forklift vehicles, power tools with internal combustion motors, and vehicle bay exhaust. Employee exposure to any air emissions that are being created in your facility must be accounted for. You may need to contact the supplier of your welding rods for help in tracking down the appropriate MSDS.
Also, do not overlook gasoline and carbon monoxide. Material safety data sheets do not have to be provided for vehicles such as lift trucks, tractors, or automobiles. However, MSDSs are required for the gasoline and other fuels used by the vehicles. Employees should be aware of the potential for exposure to carbon monoxide and associated physical hazards of petroleum fuel products such as fire and explosion.
OSHA does not specify a particular retention period for MSDSs. However, according to the Employee Access to Medical Records at §1910.1020, an employer must retain medical records, air sampling data, and other exposure information for 30 years.
While MSDSs are considered “exposure records,” OSHA is really only interested in the chemical identity, where the chemical was used, and how long the chemical was used. When developing the list of hazardous chemicals for your workplace, include information on where these chemicals were used and for how long. Storing the lists would take up much less space than storing all of the individual data sheets.
Keep a master MSDS file and check in each MSDS, particularly noting the revision date. If an MSDS is an update of a sheet that you have, then send out a copy to each department that uses the chemical, so they can update the departmental MSDS file. If an MSDS is for a new chemical, send copies to each department that will use it.
Also, monitor the MSDSs within each department. Sheets get torn out or smudged and need to be replaced. Have a cover sheet listing what MSDSs are in the file, along with the revision number. A supervisor can then weekly or monthly check quickly to see if all the MSDSs are there and readable. Replace missing data sheets immediately.
You may discard a superseded MSDS for a mixture, if the new data sheet includes the same hazardous chemicals as the original formulation. If the formulation is different, then you will have to keep either the MSDSs or the critical information for at least 30 years.
In order to ensure that you have a current MSDS for each chemical in your facility and that employee access is provided, OSHA looks at the following types of information in your written program:
1. Person(s) responsible for obtaining and maintaining the MSDSs;
2. How data sheets are maintained (e.g., in notebooks in the work area(s) or in a computer with terminal access);
3. How employees can access them when they are in their work area during the work shift;
4. Procedures to follow when the MSDS is not received at the time of the first shipment;
5. For producers, procedures to update the MSDS when new and significant health information is found; and,
6. Description of alternatives to actual data sheets in the workplace, if used.
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