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Published May 10, 2016

OSHA's June 1 GHS deadline for safety data sheets: What does it mean for you?

OSHA and Safety BLR.com

Since June 1, 2015, chemical manufacturers, importers, or other employers responsible for preparing safety data sheets, or SDSs, were required to format each SDS using consistent headings in a specified 16-section sequence. The revised hazard communication standard, which were amended to align with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS), requires chemical manufacturers and importers to evaluate and classify the hazardous chemicals that they produce or import for physical and health hazards and follow a new mandatory 16-section format for safety data sheets (SDSs), which were formerly called material safety data sheets (MSDSs).

Employers were required to train their workers on new label elements and the new SDS format by December 1, 2013, manufacturers, distributors, and importers of chemicals were given additional time to bring their materials into compliance with the revised standard. But as of June 1, 2015, chemical manufacturers and importers were required to have completed the transition process for SDSs. Distributors, meanwhile, had until December 1, 2015, to ensure that all shipped containers would bear a GHS-compliant label.

Summary of GHS compliance deadlines:

  • June 1, 2015: Chemical manufacturers, importers, and distributors to comply with all the requirements of the GHS rule (e.g., hazard classification, SDS format), except compliance with the GHS label requirements is optional for distributors until December 1, 2015.
  • December 1, 2015: All shipments of chemical containers should include the GHS-compliant label (signal word, pictogram, hazard statement, and precautionary statement).
  • June 1, 2016: All employers that use, handle, or store hazardous chemicals are to update alternative workplace labeling and hazard communication programs, as necessary, and provide additional employee training for newly identified physical or health hazards.

Chemical end user responsibility for updated SDSs

Note that OSHA has stated (in a February 2015 enforcement guidance memo) that the agency will not cite employers who are end users of chemicals (rather than manufacturers, importers, or distributors) for not having a GHS-compliant SDS for a chemical if the employer has not received it from its supplier. In fact, if you use chemical mixtures in your facility, the arrival of some SDSs may be delayed if the manufacturers of these products have not received SDSs themselves from upstream suppliers. However, upon receiving SDSs, you must maintain them in your facility and make them available for employees to examine.

Employers relying on SDSs supplied by a manufacturer, importer, or distributor are not liable for their accuracy as long as they have accepted the SDS in “good faith”—that is, without blank spaces or obvious inaccuracies. Employers should report inaccurate or missing information on an SDS to the chemical manufacturer or distributor.

If an employer chooses to conduct his or her own hazard classification of a chemical under the HazCom rule, the employer will be responsible for the accuracy of the SDS.

Prepare for new SDSs

When a new SDS arrives at your division, the person who is in charge of your hazard communication program should review it and compare it to the old MSDS. Look for any newly identified hazards, changes in hazard classification, changes to recommended safe work practices and personal protective equipment (PPE), and any other important updates. Make a note of any differences needed to be communicated to employees or updated in the hazard communication program.

As part of the program, employers are required to update their written HazCom programs by June 1, 2016.

SDS format

The new SDSs are required to present information in a 16-section format, with each section containing specific information about the chemical substance. The 16 sections are as follows:

  • Section 1, Identification: Identifies the chemical and its recommended uses and provides contact information for the chemical supplier.
  • Section 2, Hazard identification: Identifies the hazards of the chemical and the appropriate warning information.
  • Section 3, Composition/Information on Ingredients: Identifies the ingredient(s) contained in the product, including impurities and stabilizing additives, and states trade secret claims.
  • Section 4, First-Aid Measures: Describes first-aid measures to be taken in case of exposure, describes the most important symptoms or effects of exposure, and recommends any necessary medical care or special treatment.
  • Section 5, Fire-Fighting Measures: Recommends methods for fighting a fire caused by the chemical, including suitable extinguishing equipment, advice on specific hazards that develop during a fire, and recommendations on special protective equipment or precautions for firefighters.
  • Section 6, Accidental Release Measures: Recommends the appropriate response to spills, leaks, or releases of the chemical, including containment and cleanup practices to prevent or minimize exposure.
  • Section 7, Handling and Storage: Provides guidance on safe handling practices and storage conditions for the substance, including information on incompatibilities and general hygiene practices.
  • Section 8, Exposure Controls/Personal Protection: Indicates exposure limits, appropriate engineering controls, and recommendations and/or requirements for PPE, protective clothing, or respirators.
  • Section 9, Physical and Chemical Properties: Identifies physical and chemical properties associated with substance, including appearance, odor, pH, melting/freezing point, flash point, evaporation rate, and other relevant information.
  • Section 10, Stability and Reactivity: Describes the reactivity hazards of the chemical and the chemical stability information.
  • Section 11, Toxicological Information: Identifies toxicological and health effects, including likely routes of exposure; description of immediate, delayed, or chronic effects of exposure; and indication of whether the chemical is listed as a potential carcinogen.
  • Section 12, Ecological Information (non-mandatory): Provides information on the chemical’s environmental impact if released. OSHA will not enforce this section.
  • Section 13, Disposal Considerations (non-mandatory): Provides guidance on proper disposal practices, recycling or reclamation of the chemical and its container, and safe handling practices. OSHA will not enforce this section.
  • Section 14, Transport Information (non-mandatory): Provides guidance on classification information for shipping and transporting of the substance. OSHA will not enforce this section.
  • Section 15, Regulatory Information (non-mandatory): Identifies regulations that apply to the substance that are not indicated elsewhere on the SDS. OSHA will not enforce this section.
  • Section 16, Other Information: Indicates when the SDS was prepared or when the last known revision was made, in addition to any other information the supplier provides that is not indicated elsewhere.

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