The Global Standard for Providing Software Tools to Automate the Authoring, Management and Distribution of Material Safety Data Sheets (MSDSs) and Other Hazard Communication Documents The Wercs
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 Press Room

11/30/2007

Managing Material Safety Data Sheets in the Workplace

While regulatory agencies outline requirements for communicating chemical hazards, the format of compliance is up to the employer. Software tools can be helpful aids in meeting these requirements.


Karen E. Lintz

Wercs Professional Services, LLC


To ensure the health and safety of workers, the U.S. Occupational Safety and Health Administration (OSHA) adopted the Hazard Communication Standard (HCS) in 1983. Initially designed to protect workers in the manufacturing sector, the HCS was expanded in 1987 to cover all industries where workers could be exposed to hazardous chemicals. This article gives an overview of the OSHA requirements for material safety data sheets (MSDSs) and describes ways to meet these requirements with automated software tools.


Hazard communication program

All manufacturers and importers of chemicals are required to review the known physical and health hazards of the chemicals they make or import to determine if they are hazardous. This process is known as hazard assessment. The m anufacturers and importers must have a process for collecting and assessing this information, and then generating MSDSs. While OSHA only requires MSDSs for chemicals that are hazardous according to its definition, these data sheets are also often written for non-hazardous materials.


When the MSDSs have been developed, the manufacturer must make them available to downstream users of the chemicals, including its own employees, distributors, and customers. A written hazard-communication program is also required to share this information with employees through training and the use of MSDSs and warning labels. The written program must describe how the requirements for labels, MSDSs, and employee training are going to be met in the facility. This hazard communication program is key to meeting OSHA s requirements.


Employee training

Under the HCS, all employees have the right to know about chemical hazards in the workplace, and how they can protect themselves against both the physical and health hazards associated with exposure. Employees must know the identities of the hazardous chemicals in their workplace and where they can find the MSDSs for the chemicals.


The HCS dictates that employees be trained at least once a year, but additional training should also be conducted whenever a new hazardous chemical is introduced into the workplace. The training must include educating employees in the proper use of the hazardous chemicals. Both the physical and health hazards of the chemicals should be included, as well as information on how employees can protect themselves from exposure. Employees need to know the physical properties of the chemicals, how to detect a spill or release of the chemical, and what measures to take if a spill occurs.


Employee access to information

According to OSHA, all employees must have direct access to MSDSs for the hazardous chemicals that are in their work areas during their normal working hours. Employers must ensure that employees are provided with an MSDS for every chemical to which they may be exposed, and employees must receive training on any new chemicals before they chemicals are introduced into the workplace. MSDSs may be provided to employees as paper copies contained in centrally located binders or through computerized systems. Alternatives to paper copies are permitted, as long as employees have immediate access to the MSDSs. Maintaining paper copies of MSDSs in a back-up method to electronic systems is often a good practice.


Information requirements

To ensure that employees can properly handle hazardous chemicals in the workplace, the HCS requires that each MSDS include information about the chemical that will allow employees to quickly identify the chemical, recognize the possible hazards of exposure, and take precautions to protect themselves against exposure. The HCS is a performance-oriented standard, which means that OSHA provides very few requirements for the format of the MSDS. However, the HCS does specify that the MSDSs must be available in English, and must include the following information:



  • The product name as it appears on the container label: This allows employees to quickly locate the proper MSDS for the chemical they are handling

  • The names of all of the hazardous chemicals in the product that are present at a concentration of greater than 1% (0.1% for carcinogens). Non-hazardous chemicals may also be listed, but full disclosure of a product s formulation is not required

  • The physical and chemical characteristics of the chemical, such as its physical form, color, odor, flash point and vapor pressure: To ensure safe handling, employees must be able to recognize how a product is supposed to look and behave

  • The physical hazards of the product, such as flammability and reactivity: This information may be important for proper handling, storage, and disposal of a chemical

  • The known acute (immediate or short-term) and chronic (long-term) health hazards of the chemical

  • The signs and symptoms of exposure: Some chemicals do not have good warning properties, such as a smell, so employees must be able to recognize any expected health effects from overexposure to a hazardous chemical

  • Any medical conditions that may be aggravated by exposure to the chemical.: Employees with pre-existing medical conditions may need to take additional steps to ensure their safety when working with a chemical

  • The routes of exposure for the hazardous chemical: This information is important when choosing the proper personal protective equipment to be worn while handling a hazardous chemical. Severe irritants or chemicals that can be absorbed through the skin may require specific gloves or protective clothing, while products that are respiratory hazards may need special ventilation or respiratory protection for safe handling

  • The exposure limits for the hazardous chemical, including the OSHA permissible exposure limit, the ACGIH (American Conference of Governmental Industrial Hygienists) threshold limit value (TLV), or a recommended exposure limit developed by the manufacturer of the hazardous chemical: This information is critical to ensure that employees are not overexposed to hazardous chemicals during their workday

  • The classification of the chemical as a known or potential carcinogen by OSHA, NTP (National Toxicology Program), or IARC (International Agency for Research on Cancer)

  • Precautions for safe handling and use, including hygiene practices and clean-up procedures

  • Appropriate engineering controls and personal protective equipment

  • Emergency and first aid procedures

  • The date the MSDS was prepared

  • The name, address, and telephone number of the party responsible for preparing the MSDS


The MSDS may also provide additional regulatory information for the hazardous chemical. SARA (Superfund Amendments and Reauthorization Act) hazard classifications, CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act) reportable quantities (RQs), transportation information, global inventory compliance, and environmental hazards or effects are often included in MSDS. When these document are written to the ANSI (American National Standards Institute) standard guidelines, they will meet OSHA requirements and provide the user with additional helpful toxicology and regulatory information.


Updating the MSDS

In the US, there is no specific timeframe requirement for updating MSDSs. When the document is prepared, it must include the most up-to-date information about the chemical hazards based on the available scientific evidence at that time. If a manufacturer becomes aware of new significant information regarding a chemical s hazards, the manufacturer has three months to update its MSDS. This updated version must be provided to customers with the next shipments of the hazardous chemical. To ensure compliance with this requirement, manufacturers must closely monitor global chemical regulations as well as new reports of adverse health or environmental effects associated with chemical exposure.


MSDS management software

While there are no requirements for generating MSDSs through specific software, many companies utilize software tools or programming to produce and manage their MSDSs.

Using dedicated MSDS management software has several distinct advantages over word processing: increased MSDS-production efficiency, enhanced MSDS-language consistency, better formulation management, and ease of distribution.



  • Global market

    • In today s global market, having a system that supports alternate templates and languages to meet the requirements for specific regions or countries is a must. All global product information can be stored in MSDS management software, allowing for the quick and easy production of MSDSs for any country or region.



  • Rules or logic tools

    • Automated tools can decrease the need for manual data entry and manipulation. By using appropriate software, information can be automatically entered into the MSDS based on system rules or logic. This not only increases the efficiency of MSDS production but the consistency of MSDS information as well.



  • Impact of regulatory changes

    • The impact of changes in regulations can be quickly determined through the use of automated impact analyses and update tools. These tools can ensure that all affected products are reviewed, and required changes are applied appropriately. These tools can be configured to apply to local, regional, state, federal and global changes, depending on the needs of the user.



  • MSDS distribution tools

    • Automated MSDS distribution tools are also a very useful part of an automated system. MSDSs can be automatically mailed, faxed, e-mailed, or sent to a web viewer based on pre-set criteria.




Looking Forward

Requirements for MSDSs will continue to grow and change. New initiatives, regulations and health-effect information make it necessary for regulatory professionals to continually be on the lookout for anything that may impact their MSDSs. New guidelines or classification systems, such as the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), will impact how we communicate and classify information. Regulatory professionals must keep abreast of not only the OSHA requirements for MSDSs, but also global requirements. Through proper training, procedures and automated software tools we can ensure that our employees and customers always receive the most up-to-date information for the chemicals they use.


Author


Karen Lintz is the director of regulatory services for Wercs Professional Services (WPS); (Phone (800) 572-6501 or (518) 640-9220; Email: info@thewercs.com; Fax; (518) 640-9299) where she provides regulatory guidance in support of software content and implementation. Prior to this position, Lintz was a regulatory specialist at GE Silicones. In earlier positions, Lintz followed patients in human clinical cancer-treatment trials as a study coordinator at the Cancer Center of Albany Medical Center, developed and reviewed clinical protocols and case report forms as a data manager at Frontier Science and Technology Research Foundation, Inc., and worked as a product safety specialist at the Carborundum & Advanced Materials Division of BP Chemicals. Lintz holds a BA in biology from Lycoming College and an MA in pharmacology, toxicology, and therapeutics from the State University of New York at Buffalo.