OSHA’s HazCom 2012 chemical safety standard requires companies to maintain a Safety Data Sheet (SDS). That sounds similar to the old Material Safety Data Sheet (MSDS), so what’s the difference?
History of MSDS and SDS
Under OSHA’s rules for workplace chemical safety, workers have a right to know about the hazards present in their workplace. This idea is so important that “Right To Know” (RTK) became the common name for a set of OSHA’s rules about chemical labeling. But those rules, published in 1994, didn’t require employers to use any particular format for the information they provided to workers. The result was a wide variety of approaches and a lot of confusion.
One part of the RTK rules required employers to keep a document on file for each hazardous chemical present in the facility. These documents had to provide data about the safety concerns related to each material, and so they were called Material Safety Data Sheets (MSDSs). Since OSHA didn’t require any particular format to be followed, two MSDSs for the same chemical may have looked completely different.
In 2012, OSHA published a major revision to the RTK rules, creating a new system called HazCom 2012. This regulation for chemical safety in the workplace is based on an existing international standard, called the Globally Harmonized System (GHS). One important part of the new rules requires a single, specific format to be followed in the detailed documentation for hazardous chemicals. This format is the Safety Data Sheet (SDS).
The Role of SDS
Both GHS and HazCom 2012 start by classifying the hazards of a chemical, using clearly-defined laboratory tests. Both systems end with a standardized set of useful information to be included on the container labels that employees will see during their normal work. The SDS fits between these two steps, recording the results of hazard classification and providing the detailed information that will be needed on a label, as well as the information necessary for other aspects of a chemical safety program.
Without a standardized SDS, information from the classification stage can be lost, and making an accurate container label becomes an enormous task. A complete and compliant SDS can answer any question about a chemical’s hazards, though. Using the standardized SDS format, chemical suppliers can provide the necessary information in a reliable and consistent way, and recipients of those chemicals can understand the information they need to know.
What’s the Difference Between an MSDS and an SDS?
The difference between the old MSDS and the new SDS is more than just the “M” at the beginning. While MSDSs could follow any number of different formats, and could include different kinds of information with different levels of detail, the SDS format is much stricter. An SDS is made up of sixteen sections, each of which must include specific information using a standardized classification method.
There is likely to be a lot of overlap between an MSDS and an SDS for a given chemical. For instance, a flammable liquid will probably have its flash point noted on both forms. But converting from MSDS to SDS may not be easy.
Not all of the details required for an SDS may have been included on the old MSDS. Because there are dozens of ways to organize an MSDS, it may take a careful reading to find out which details are missing.
If moving from an MSDS to an SDS is more than a simple translation, how are businesses supposed to make the change? Fortunately, the process is simpler than you may think.
Request an SDS from Your Supplier
If your hazardous chemical is provided by an outside organization, that organization is responsible for providing an updated SDS. You may have already received an updated SDS along with your recent shipments. If not, you can request a current SDS by contacting that chemical supplier. Many suppliers provide these forms on their websites, as well.
“Translate” from MSDS to SDS
If your facility produces the chemical in question, you’ll need to make an SDS yourself. This isn’t so much about “translating” from one format to another as it is “filling in the blanks.” Don’t start with your existing MSDS and try to translate it; instead, start with a listing of the details that you need, and copy items over from the existing MSDS. You may find that you don’t have some of the elements that are required. If so, those will be the points that you need to find test results for.
In general, every chemical in a workplace that poses a hazard defined by the HazCom 2012 system will need to have an SDS on file in that workplace. Each SDS needs to have 16 sections, organized in a specific, logical sequence.
The first three sections give the most basic and important information. They identify what the material is, what hazards it poses, and what important ingredients it includes:
1. Material Identification
2. Hazard Identification
3. Composition Information
The next several sections talk about how workers may need to deal with the material, starting with the most urgent concerns, and working down to day-to-day safety:
4. First-Aid Measures
5. Fire-Fighting Measures
6. Accidental Release Measures
7. Handling and Storage
8. Exposure Controls and Personal Protection
Next, the SDS goes into detail about the nature of the material itself, and where its hazards come from:
9. Physical and Chemical Properties
10. Stability and Reactivity
11. Toxicological Information
The next group of sections cover concerns that are not part of OSHA’s jurisdiction. These sections are still required parts of the standard SDS format, but their contents are more relevant to other government agencies:
12. Ecological Information
13. Disposal Considerations
14. Transport Information
15. Other Regulatory Information
Finally, there’s a catch-all section for details that might not fit somewhere else, especially information about the document itself — like the date when the SDS was prepared:
16. Other Information
OSHA lists out these sections, along with the details that need to be included, in Appendix D to the HazCom 2012 regulations. You can use that listing as a framework for your own SDS, filling in the blanks to create a complete and compliant Safety Data Sheet. You can also request a free reference chart from Graphic Products describing the new SDS format, and showing how its sections correspond to OSHA’s HazCom 2012 labeling system.