Let’s Talk About Hazardous Communication

Knowing what chemicals you might touch or breathe in your workplace is very important. Every time you pick up a spray can to paint, lubricate, or clean, you start the chemical exposure process. Have you read the labels on those cans? Have you read the Safety Data Sheet (SDS) for each chemical? The labels and SDS are part of the Hazardous Communication Standard (HCS).

Even chemicals that other people use can contaminate the air you breath or the surfaces you touch. Chemicals used by production equipment — whether in open vats or flowing through pipes — can pose a hazard.

OSHA created the HCS in 1989. If you look in the Code of Federal Regulations, you will find it under 29 CFR 1910.1200(g). The HCS sets standards for manufacturers of hazardous chemicals and for the employers of those working with chemicals. The intent is to provide you with the hazard information you need to protect yourself.

SDS

The HCS requires the chemical manufacturer, distributor, or importer of chemicals to provide a specific type of data sheet to users. The data sheet communicates information on specific hazards and the safety information to address those hazards.

A chemical does not have to be by itself to be subject to the HCS. If it is incorporated into a product such as a battery, the battery is subject to the HCS. Since all batteries use toxic materials, they all have a data sheet.

What is this data sheet called? Until 2012, it was called the Material Safety Data Sheet (MSDS). In 2012, however, two initiatives resulted in changing the sheet and in changing its name to Safety Data Sheet.

One was harmonization with Europe, a trend with many standards. The other was to make it easier to understand and use.

The MSDS was not consistently structured, which meant that the same chemical could have a significantly different-looking MSDS from one manufacturer to the next. The section on personal protective equipment (PPE) might be near the top on one and near the bottom on another. Or the PPE information might not even be in its own section. The layout was all over the place.

The SDS has a user-friendly, consistent 16-section structure. With the SDS, you can go right to the section you need, rather than become frustrated trying to find where they buried the ventilation requirements. Once you’re familiar with the format, your efficiency in using the SDS goes up — and so does your accuracy. Let’s see what’s in each section.

Section 1: Identification. This section provides:

• The product identifier, name(s) of the chemical, and its recommended uses.
• Name, address, phone number of the manufacturer or other responsible party, and emergency phone number.

Section 2: Hazard(s) Identification. This provides:

• Hazard classification (e.g., flammable liquid).
• Signal word (either “Danger” or “Warning”).
• Hazard statement(s). For example, “Code H202: Explosive; severe projection hazard.”
• Pictograms (e.g., skull and crossbones, flame).
• Precautionary statements, such as advice on correct handling.
• Description of hazards not otherwise classified.
•  If the chemical contains an ingredient with unknown toxicity, a statement describing what percentage of the total mixture has acute toxicity.

Section 3: Composition/Information on Ingredients. This identifies the ingredients indicated on the SDS, including impurities and stabilizing additives.

For substances, it discloses:

• Chemical name.
• Common name and synonyms.
• Chemical Abstracts Service (CAS) number and other unique identifiers.
• Impurities and stabilizing additives, which are themselves classified and contribute to the classification of the chemical.

For mixtures, it discloses:

• Same information as for substances.
• Chemical name and concentration of all ingredients that are classified as health hazards and are present above their cutoff/concentration limits or present a health risk below the cutoff/concentration limits.
• The concentration (exact percentages) of each ingredient.

For that last item, concentration ranges may instead be used if:

• A trade secret claim is made,
• There is batch-to-batch variation, or
• The SDS is used for a group of substantially similar mixtures.

Section 4: First-Aid Measures. This describes the initial care untrained responders should give to an individual exposed to the chemical. The required information includes:

• Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, and ingestion).
• Description of the most important symptoms or effects, and any symptoms that are acute or delayed.
• Recommendations for immediate medical care and special treatment.

Section 5: Fire-Fighting Measures. This includes:

• Recommendations of suitable extinguishing equipment.
• Information about situation-inappropriate extinguishing equipment.
• Advice on specific hazards that develop from the chemical during a fire.
• Recommendations on special protective equipment or precautions for firefighters.

Section 6: Accidental Release Measures. How do you respond to spills, leaks, or releases, including containment and cleanup practices to prevent or minimize exposure to people, property, or the environment? You find the answers here, including:

• Use of personal precautions and protective equipment to prevent contaminating skin, eyes, and clothing.
• Emergency procedures.
• Methods and materials for containment.
• Cleanup procedures.

Section 7: Handling and Storage. This includes:

• Precautions for handling incompatible chemicals.
• How to minimize the release of the chemical into the environment.
• Recommendations for safe storage.

Section 8: Exposure Controls/Personal Protection. This section indicates the exposure limits, engineering controls, and personal protective measures you can use to minimize worker exposure.

• Exposure limits, such as OSHA Permissible Exposure Limits (PELs) or Threshold Limit Values (TLVs).
• Appropriate engineering controls (e.g., local exhaust ventilation).
• Recommendations for personal protective measures to prevent illness or injury from exposure.
• Any special requirements for PPE.

Section 9: Physical and Chemical Properties. This section identifies physical and chemical properties associated with the substance or mixture. The minimum required information consists of 18 items, including appearance (physical state, color, etc.), pH, flash point, and flammability, but only as applicable to the chemical in question.

Section 10: Stability and Reactivity. This section describes the reactivity hazards of the chemical and the chemical stability information. This section consists of three parts: reactivity, chemical stability, and other.

“Other” can be detailed. It must describe the possibility of hazardous reactions, including a statement whether the chemical will react or polymerize. It must also list all:

• Conditions to avoid (e.g., static discharge or shock).
• Classes of incompatible materials.
• Known or anticipated hazardous decomposition products that could be produced because of use, storage, or heating.

Section 11: Toxicological Information. Among other helpful items, this section provides:

• Information on the likely routes of exposure (e.g., inhalation).
• Description of the delayed, immediate, or chronic effects from short- and long-term exposure.
• The numerical measures of toxicity, such as the LD50 (median lethal dose).
• Description of the symptoms, including those from the lowest to the most severe exposure.

The following five sections are not mandatory, so one or more might not appear in a given SDS:

Section 12: Ecological Information. This helps you evaluate what harm the chemical may cause if it were released to the environment. The information may include data from toxicity tests and details such as endocrine disrupting potential.

Section 13: Disposal Considerations. This should provide guidance on proper disposal practices, recycling or reclamation of the chemical or its container, safe handling practices, and special precautions for landfills or incineration.

Section 14: Transport Information. This should provide guidance for transporting hazardous chemicals by road, air, rail, or sea. It may include information a shipper will request, such as the UN number. It will also state any special precautions an employee should be aware of or comply with, inside or outside their premises.

Section 15: Regulatory Information. Here, you will find the product-specific safety, health, and environmental regulations not indicated elsewhere on the SDS. For example, OSHA or DOT regulations.

Section 16: Other Information. It states when the SDS was prepared or last revised. It may indicate where the changes have been made to the previous version. You may wish to contact the supplier for an explanation of the changes. Other useful information also may be found here.

Beyond the core

While the SDS is the core tool of the HCS, the HCS consists of five tools:

1. Hazard evaluation. The manufacturer evaluates a given chemical to determine what specific hazards it may pose.
2. Warning labels. Labels include body-part specific information. A label may have one warning about your eyes and another about your skin.
3. Safety Data Sheets (SDS). The focus of this article.
4. Employee training. Do you find it helpful? If not, the training program violates the intent of the HCS law. Ask your management to correct the deficiencies.
5. Written program. Read your employer’s program. If something is unclear, ask management to clarify.

To best avail yourself of the HCS, use those last four tools with your full attention at every step. Don’t just glance at a label; read it carefully, and use what you learn. When in doubt, seek clarification.

Lamendola is an electrical consultant located in Merriam, Kan. He can be reached at [email protected].