When the Occupational Safety and Health Administration (OSHA) enacted the Hazard Communication Standard (HCS) in 1983, the chemical manufacturing and distribution industries were the most affected by the broad sword of complying with the regulations. At the heart of this standard, is the idea that all employees have a right to know what the chemicals and associated hazards are in their workplace.
To that end, chemical manufacturers and importers must convey both physical hazards (such as flashpoint, flammability, explosivity), and the health hazards (carcinogenicity, birth effects, etc) of their end products. This is achieved using Material Safety Data Sheets (MSDSs). One problem with MSDSs stems from the fact that the HCS is a performance-based standard, meaning that the employer is allowed flexibility in adapting rules to the needs of the workplace versus rigid compliance requirements. In fact, the standards are so flexible that OSHA has no specified format for the MSDS other than what information should be included. With over 3 million MSDSs written since the Standard was enacted, the variability in quality and formatting is staggering.
Few Common Standards (back to top)
As a manager charged with complying with the HCS, one might expect to see MSDSs varying in length from 4 or 5 pages to as many as 20. Moreover, manufacturers often include so many health hazards that the average worker would need a doctorate in toxicology just to decipher the informationdefeating the purpose of the standard in the first place. Manufacturers should not be blamed for this "kitchen sink" mentality of placing every conceivable hazard into a MSDS; this is only a natural tendency to anticipate the inherent liabilities of chemical use.
While it may seem that a toxicologist would be the ideal person to prepare a MSDS, it is simply a matter of knowing how the end user of the chemical will interpret the data. For example, many compounds lack in-depth toxicological studies done on humans, and as a result, one must rely on animal studies for the toxicity information. Rather than delving into dose-response curves and lethal dose calculations, a good MSDS writer will cite authoritative data from agencies. These agencies include OSHA, the American Council of Governmental Industrial Hygienists (ACGIH), and the National Institute of Occupational Safety and Health (NIOSH). Exposure values for a compound are based on a worker's exposure to the chemical in an eight-hour workday. Clearly, someone in charge of MSDS preparation could be a CHMM, CIH, CSP, or PE with an extensive background in workplace environmental, safety and hygiene principles.
Voluntary MSDS format (back to top)
In an effort to combat some of the quality problems with MSDSs, the Chemical Manufacturers Assn. came up with a 16-section voluntary MSDS format in 1993. The American National Standards Institute (ANSI) approved of this format and published standard Z400.1-1993, "American National Standard for Hazardous Industrial ChemicalsMaterial Safety Data SheetsPreparation."
The 16 sections of an MSDS prescribed by the ANSI standard are as follows:
Although these standards were supposed to introduce a level of consistency in MSDSs, OSHA has yet to amend the initial HCS. For a chemical manufacturer, it is recommended that the ANSI standard format be used for MSDSs because the information can be readily found in specific sections and employee training can be facilitated with consistent data sheets. The ANSI standard is also recommended for those manufacturers who export their products overseas, because many nations rely on the format for their own compliance with local regulations. It is important to remember that while the ANSI standard is a good format, it is only a recommended one, and at a minimum, you must include all OSHA required information because the OSHA standard is legally enforceable.
Once a chemical manufacturer prepares the MSDS, the ultimate responsibility for approval lies with the company's director. Any questions from a chemical user must be directed to officials at the company who are familiar with the contents of the MSDS. OSHA does not offer any review services, even though the agency will issue citations and fines for incomplete or missing information. A multi-disciplined approach using a company's legal, safety, and other resources can ensure that compliance with the HCS is maintained.
What can the chemical manufacturer do to avoid common pitfalls associated with MSDSs? Review your current MSDS. Does it at least meet the OSHA criteria for providing specific health and physical hazard information? If you are unsure, do you know where to go for updating the information? If your in-house environmental, health, and safety resources are limited, it may be wise to utilize the services of a consultant who is versed in the nuances of the regulations.
Work With Experts (back to top)
At <%=company%>, our clients provide us with the chemical and physical properties of their particular product. If the product is new and no prior testing has been performed on the chemical, we can arrange for the analysis. In order to protect the client's proprietary claim on the product, a confidentiality agreement is entered into prior to work start-up. Depending on the needs of the client, a draft MSDS formatted with ANSI, OSHA, and worldwide regulatory requirements can be prepared within 24 hours and delivered via email, fax, and hard copy. With feedback from the client, the MSDS is then reviewed for errors and omissions, and the document becomes finalized. If a client has an outdated MSDS, <%=company%> provides updating services as well.
If a chemical manufacturer has a thoroughly prepared MSDS, the overall effectiveness of the Hazard Communication program can be improved as workplace users of the product are given the most accurate and pertinent safety data.
Atanu Das is president of <%=company%>.com, a company providing Material Safety Data Sheet preparation and updating, hazard communications training and labeling services:
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