GHS HazCom: A Webinar Spotlight on SDS Compliance
Posted on February 9, 2022 | in EHS
An employee works 35 years for a company operating a dip tank. He spends his days washing grease off equipment parts without protection, not knowing what types of chemicals are in the solvent he uses. After performing his job function over these 35 years, he learns his short-term memory has been heavily impacted due to chronic exposure to toluene, an ingredient in the solvent.
Chronic exposure to toluene at concentrations of 200 to 500 ppm has been reported to cause loss of coordination, memory loss, and loss of appetite. In this case, the employee lost his short-term memory. His wife had to double as his caretaker because he was unable to remember how he got from one place to another and had lost some of his capacity for self-care. His exposure to this chemical not only impacted his life, but his wife’s life as well.
This was a story told by Phil Molé, MPH, our VelocityEHS EHS and Sustainability Expert during our recent webinar, GHS-HazCom: Maintaining Compliance and Preparing for the Future. In this webinar, he takes a deep dive into the importance of maintaining compliance with OSHA’s HazCom Standard, which OSHA originally issued because of too many stories like that of the employee mentioned above. The webinar discusses many facets of HazCom compliance, but in this post, we will focus on how compliance with Safety Data Sheet (SDS) requirements enables employees to better understand the hazards of chemicals they work with, and avoid negative impacts to their health.
If you’d like to take in all the insights about-HazCom Compliance from the full webinar, Click Here to watch it on-demand.
A Little Background on OSHA Hazard Communication
OSHA’s HazCom regulations protect 43 million workers and 5 million workplaces from hazardous chemicals. OSHA initially adopted HazCom in 1983 and has revised it several times over the years. The most recent revision went into effect in 2012 when OSHA aligned the Standard with Revision 3 of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), developed by the UN. This new system allows for a common and coherent global approach to classifying, defining, and communicating chemical hazards.
This revision had a large impact on how chemical manufacturers now format SDSs. The SDS provides much needed information about workplace chemicals, so employees can know and understand what chemicals they are working with and avoid situations like the above story. SDSs are a source of information about hazards, including environmental hazards, and guidance on safety precautions during handling and storage. Always remember employees have a Right-to-Know and a Right-to-Understand the HazCom such as what is on an SDS, and how to access them without barriers.
Sections of an SDS
The current HazCom 2012 GHS-aligned SDS format consists of 16 sections. Sections 1–11 and 16 are mandatory and chemical manufacturers must include the information within them. Sections 12–15 are not mandatory in terms of content based on the HazCom Standard, but OSHA still requires chemical manufacturers to have the numbers and headings in the correct order on the SDS. The breakdown of the sections and exact order are:
- Chemical and Company Identification
- Hazard(s) Identification
- Composition/Ingredient Information
- First-Aid Measures
- Fire-Fighting Measures
- Accidental Release Measures
- Handling and Storage
- Exposure Control/Personal Protection
- Physical & Chemical Properties
- Stability & Reactivity
- Toxicological Information
- Ecological Information
- Disposal Considerations
- Transport Information
- Regulatory Information
- Other Information
There are some sections that may require special attention. For instance, in Section 1, Chemical and Company Identification, in the US, OSHA has clarified that you cannot have a responsible party with a foreign contact, it must be a domestic address and phone number. The danger lies in the event of someone needing to dial the emergency phone number in a foreign format, which may cause a delay in getting needed information, and potentially very serious consequences.
In Section 2, Hazard(s) Identification, Danger and Warning are the only two signal words that can be used, with the specific word depending upon the classification. Using all the correct hazard pictograms in this section is another area that can be easily overlooked. While Section 2 does not need to include the hazard pictograms in the exact full-color format they have on the shipping label, they at a minimum need to name the appropriate pictograms corresponding to the classification.
Remember, the reason OSHA requires chemical manufacturers to supply SDSs to downstream users and requires employers to maintain SDSs for all chemicals and provide access to them is to ensure that users of chemicals have the information needed to work safely with them. The point of keeping and maintaining an SDS database is to inform the safe handling and storage of chemicals, which means you should actually use the information in the SDS. For example, when some chemicals mix there are dangerous situations that arise from incompatible chemical reactions, and we need to know what to avoid.
Section 7, Handling and Storage, is the resource to use on an SDS to get key information you and your employees need so that they know how to handle and store chemicals properly. For example, you’ll learn which chemicals are incompatible with your product, specific storage practices (such as temperature ranges for storage areas) and whether the containers need to be bonded and grounded.
A great way to manage your SDS inventory is to do a thorough chemical inventory check and repeat as needed. Use this list to manage and update your SDS catalog. And remember that SDSs need to be accessible to employees, and your employees must know how to access them.
As for your method of storing SDSs, you can use electronic systems, including cloud-based software. You just need to make sure that you can print hard copies upon request, and that there’s a backup system in place for foreseeable emergencies. Many modern SDS management software systems come with several readily available backup options, like faxback services.
The Big Picture
SDSs are just one important component of having your GHS HazCom program in compliance. Here are a few high-level takeaways:
- Have an SDS for every hazardous chemical in your inventory
- Keep communication open with the supplier of the chemicals and ensure you have the most current SDS
- Maintain an up-to-date SDS inventory
- Train your employees to know how to read SDSs and how to access them
Having the knowledge and understanding of hazardous chemicals that comes with better SDS access and management, makes stories like the one above involving the dip tank operator less likely to happen. HazCom isn’t just a regulatory obligation. It’s a key part of our efforts to make sure that our employees go home safely every day.
VelocityEHS Can Help!
When it comes to chemical hazard communication, VelocityEHS is the industry leader. Our award-winning VelocityEHS Chemical Management solution has helped tens of thousands of customers and millions of users worldwide simplify compliance with hazardous communication requirements and improve workplace chemical safety. We can give you the support you need to keep your chemical inventory and SDS library up-to-date and provide easy access to all your SDSs from anywhere using your mobile devices.