MOTIVATION
(Material) Safety Data Sheet ((M)SDS) documents provide both workers and emergency personnel with the proper procedures for handling or working with a particular substance. Due to their crucial role in public health and safety, chemical and food manufacturers and importers are required by law to provide SDS documents for each of their products. National and international regulations require that SDS documents not only be technically accurate, but that they also follow strict guidelines for formatting and specific wording.
The Globally Harmonized System (GHS) was established in 2003 by the United Nations to define an internationally standardized way to effectively communicate hazard information by:
- Standardizing hazard definitions into specific, well-defined categories;
- Standardizing hazard warning and precaution statements;
- Standardizing pictograms for SDS documents and product safety labels;
- Standardizing SDS format and information.
In addition to meeting legal obligations, providing SDS documents that follow the GHS guidelines will:
- Reduce risk and liability by ensuring that workers and emergency personnel have accurate information regarding the hazards and appropriate precautions/responses for each product;
- Reduce costly delays for import/export by improving compliance with international and foreign customs regulations;
- Improve customer relationships by showing a commitment to environmental health and safety and professionally and accurately providing product information. The GHS standards have already been adopted in various forms by many international jurisdictions.
In the United States, GHS compliance has been voluntary until recently. However, on March 26, 2012 OSHA published its revised Hazard Communication Standard (29 CFR 1910.1200), incorporating GHS elements into its SDS regulatory requirements. This standard officially went into effect on May 25, 2012. The United States Department of Transportation (DOT), the Environmental Protection Agency (EPA), and the Consumer Product Safety Commission (CPSC) are also working to incorporate GHS standards into their policies.
This updated rule REQUIRES ACTION from ALL employers in the United States, as well as all chemical manufacturers/distributers providing products to US companies. According to OSHA:
The new hazard communication standard still requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing safety data sheets. However, the old standard allowed chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets.
DEADLINES
Responsibilities of Employers under the final OSHA rule are:
Continuously, beginning now
Update your MSDSs to the new GHS-compliant SDSs as they become available from each manufacturer.
Deadline: December 1, 2013
Train your employees on the new label elements and the new SDS format.
Deadline: June 1, 2016
Update workplace labeling and your hazard communication program to use GHS-compliant labels and SDSs.
NOTES
OSHA’s new implementation of the HCS explicitly uses the ACGIH Threshold Limit Values (TLV) to determine if a chemical is hazardous and regulated. An unintended consequence of this official ruling is that employers may be bound to the lower ACGIH TLVs instead of the OSHA OELs, since OSHA now officially/legally supports the ACGIH TLVs.
LET CEM WORK FOR YOU
Due to significant differences with existing OSHA and ANSI standards, compliance with the new GHS-based standards will generally require authoring completely new SDS documents. OSHA’s Hazard Communication Standard is currently a performance-oriented standard, while GHS is strictly a specification-based standard. Consequently, the design, organization, wording, and content of SDS documents that were compliant with the previous OSHA and ANSI standards will be significantly different under the new standards. A complete and accurate SDS must incorporate information from numerous outside sources such as chemical toxicology databases and national and international regulatory organizations. Each product must also be evaluated, classified, and labeled using the strict GHS criteria.
Our goal is to efficiently create and maintain globally-compliant SDS documents in today’s ever-changing marketplace. As you can see, this is not a small task. Our technical team is well-equipped to deliver accurate, professional, and GHS-compliant SDS authoring. You will have confidence that your SDSs comply with the new US regulations, as well as established international standards to allow import/export of your products.
Certified Environmental Management has nearly 25 years of experience in industrial hygiene, health, and safety. Our team of experienced professionals average over twenty years of industrial hygiene experience, so we can provide invaluable technical support with direct answers to complex questions. In addition, our Quality Assurance Manual is available to all clients and follows guidelines established by the American Industrial Hygiene Association (AIHA). We are proud to be designated as a US Homeland Security Laboratory for the eighth consecutive year, as well as an OSHA VPP Star Site. Taken together, our extensive experience, licensing, and commitment to excellence gives our customers added value and utmost confidence in the technical accuracy, overall quality, and regulatory compliance of our solutions.