Everything You Need to Know about Safety Data Sheets

Everything You Need to Know about Safety Data Sheets

Safety Data Sheets are critical to informing employees of the hazards they face.

Over each of the past seven years, hazard communication (1910.1200) has been one of the top five most penalized OSHA standards. But concentrating your efforts on maintaining safety data sheets (SDSs) can help. And that’s because a major component of any worksite’s hazard communications plan is its SDS.

But what is an SDS and why are these sheets integral to an employer’s hazard communications plan? This article will answer the questions you have about SDSs, how you can maintain them and why doing so protects your entire workforce.

What are Safety Data Sheets?

An SDS is a 16-section source of information relating to a hazardous chemical in the workplace. OSHA standardized the number of sections in 2012 when it revised its Hazard Communication Standard to align with the UN’s global chemical labeling system.

One of the other revisions that came in 2012 was the name change from material safety data sheet to safety data sheet. Prior to this update in 2012, an MSDS could have various formats and sections. But today, an SDS must follow a clear format.

For example, the information a worker needs to access in the event of an emergency—like the chemical name, its hazards and first aid procedures—must be stored at the beginning of an SDS. The more technical details, like handling and storage measures, should be kept in the later sections.

Listed below are the individual sections you need to ensure a SDS includes:

  • Section 1: Identification
  • Section 2: Hazard(s) identification
  • Section 3: Composition / information on ingredients
  • Section 4: First aid measures
  • Section 5: Fire-fighting measures
  • Section 6: Accidental release measures
  • Section 7: Handling and storage
  • Section 8: Exposure controls / personal protection
  • Section 9: Physical and chemical properties
  • Section 10: Stability and reactivity
  • Section 11: Toxicological information
  • Section 12: Ecological information
  • Section 13: Disposal considerations
  • Section 14: Transport information
  • Section 15: Regulatory information
  • Section 16: Other information

Of note: OSHA does not enforce sections 12 through 15—that falls on other agencies. This does not mean you can get rid of these sections, though. Other government agencies may evaluate that information at a different time than your site’s OSHA inspection.

When Do You Need a Safety Data Sheet?

OSHA uses the term “hazardous chemical” to identify which substances require SDSs on your site. But what exactly is a “hazardous chemical”?

OSHA defines it as “any chemical that poses either a physical hazard (such as flammability) or a health hazard (such as causing damage to the skin or eyes).”

So what about commercial products, like Clorox or Lysol?

OSHA provides guidance on these, as well (1910.1200(b)(6)(ix)). When employees use consumer products in the same manner and at the same frequency a consumer uses them, you don’t need an SDS for those products.

But this exemption doesn’t apply when employees work with hazardous chemicals in a manner greater than what a normal consumer would experience. In this case, employees have a right to know about the properties of those hazardous chemicals and have access to an SDS for those products.

As an example, let’s say you have Windex on your site. People use Windex to clean their homes. But if your team works with Windex frequently that it exceeds the amount an average consumer uses, you must provide an SDS for your site’s Windex.

In other words, an SDS exemption is based on the workplace’s use of the product, not just the manufacturer’s intended use.

How Should You Maintain Safety Data Sheets?

It’s incumbent on employers to maintain the current version of the SDS for every hazardous chemical on their site. Even though you should request an SDS every time you purchase a hazardous chemical from a supplier or manufacturer, you may at some point need to update or create them yourself. There are a few reasons why:

  • The supplier or manufacturer sends you an SDS that isn’t compliant (e.g., they send an MSDS, not an SDS).
  • The supplier or manufacturer has changed its formula since you last purchased the product.
  • New hazard information for a chemical on your worksite comes out.
  • Keeping your SDSs updated might sound tedious, but it keeps your worksite OSHA-compliant and, more importantly, it keeps your workers safe.

Let’s say one of your employees is exposed to Clorox Bleach. Your team leaps into action and consults the bleach’s SDS—but it’s six years old. For all you know, Clorox could have changed its formula in the time since. Because your team is working from older information, the affected employee might not receive the care they need. And that can be very dangerous, both for your employee and any first responders.

Maintaining your SDSs takes more than updating the formatting and information, though. So here are two additional steps that go into maintaining your SDSs and keeping your worksite safe.

  1. Designating an SDS Manager. Keeping track of new OSHA guidelines and changing product formulas takes a lot of work. That’s why you should assign these tasks to an SDS Manager. Your SDS Manager is the person responsible for obtaining and updating your SDSs, which means the role generally isn’t a fit for an entry-level employee. After all, this position requires a keen awareness of your worksite and familiarity with OSHA guidelines.

If you have a larger hazard communications program, you might decide to delegate the SDS management tasks to your program manager instead. A hazard communications program manager often oversees and executes the requirements of your program (which includes SDS management tasks).

  1. Training your employees. OSHA’s Hazard Communication standard (29 CFR 1910.1200(a)) details the chemical hazard information that employers must offer to employees. Specifically, OSHA notes that employers must “train employees on the hazardous chemicals in their work area before initial assignment and when new hazards are introduced. It’s critical that workers understand they are exposed to hazardous chemicals, know how to read labels and SDSs, have a general understanding of the information provided, and know how to access related tools.”

Put differently, training is an ongoing process. While offering it certainly achieves compliance, the more important result is a well-informed workforce that can easily spot hazards at your site.

Here are several elements your training should cover:

  • How to comprehend the information in SDSs and access them quickly.
  • Which measures employees should take to protect themselves, such as wearing the correct PPE and understanding emergency procedures.
  • How to understand the labels received on shipping containers and that supplier’s or manufacturer’s labeling system.

Just as important as the content of your training program is how you administer it. For instance, think of how your team members learn best, whether it be via real-life examples of a chemical exposure or printed how-to guides. Make sure to also consider how frequently your team needs refresher courses. And remember to offer any relevant training to contractors you may bring onsite, as well.

The goal of an effective training program isn’t to give employees materials to read; it’s to ensure each employee comprehends the material and understands how to build a safe workplace.

Where to Store Safety Data Sheets

OSHA notes that “employers must ensure that the SDSs are readily accessible to employees for all hazardous chemicals in their workplace.”

What does “readily accessible” mean? In the past, many employers addressed this by filing their SDSs in a binder located in the work area. But as technology has developed, employers have started to file their SDSs in online databases.

While an online database helps employers more easily store and recover versions of SDSs, it’s important that every employee can access them. This means that if you use an online database, each employee should know the login credentials and how to access the SDSs within seconds.

Your site may choose to delegate accessing the SDSs to your SDS Manager, but it’s important that every employee could access these sheets if needed. Failing to do so could result in an OSHA violation.

Establishing a Culture of Safety Requires Buy-In from Every Member of Your Organization

SDSs are the go-to place for hazardous chemical information at your worksite. Without them, you lose the resource that helps you properly assess chemical emergencies, administer care and dispose of any chemicals safely.

This is why maintaining your SDSs is so crucial.

Although an emphasis on safety needs to come from the top, it takes your entire team to adopt it. Each component of your hazard communications—from correctly filing SDSs in an accessible location to regularly conducting safety training—requires your team’s support and energy.

No, you don’t want to incur a penalty from OSHA. But the more serious concern is always going to be your team’s health. Establishing a culture of safety that complies with OSHA guidelines helps you protect your worksite and your employees.

This article originally appeared in the December 1, 2022 issue of Occupational Health & Safety.

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