The MSDS – Steer Clear of Potential Hazcom Roadblocks

                When the Occupational Safety and Health Administration (OSHA) enacted the Hazard Communication Standard (HCS) in 1983, the chemical manufacturing and distribution industries were the most affected by the broad sword of complying with the regulations.  At the heart of this standard, is the idea that all employees have a right to know what the chemicals and associated hazards are in their workplace. To that end,  chemical manufacturers and importers must convey both physical hazards (such as flash point, flammability, explosivity), and the health hazards (carcinogenicity, birth effects, etc) of their end products.  This is achieved using Material Safety Data Sheets (MSDSs).  One problem with MSDSs stems from the fact that the HCS is a performance based standard, meaning that the employer is allowed flexibility in adapting rules to the needs of the workplace versus rigid compliance requirements.  In fact,  the standards are so flexible that OSHA has no specified format for the MSDS other than what information should be included.  With over 3 million MSDSs written since the Standard was enacted,  the variability in quality and formatting is staggering.    As a manager charged with complying with the HCS,  one might expect to see MSDSs varying in length from 4 or 5 pages to as many as 20.  This combines with the fact that manufacturers often include so many health hazards that the average worker would need a doctorate in toxicology just to decipher the information—defeating the purpose of the standard in the first place.  Manufacturers should not be blamed for this “kitchen sink” mentality of placing every conceivable hazard into a MSDS,  this is only a natural tendency to anticipate the inherent liabilities of chemical use. While it may seem that a toxicologist would be the ideal person to prepare a MSDS,  it is simply a matter of knowing how the end user of the chemical will interpret the data.  For example,  many compounds lack in-depth toxicological studies done on humans, and as a result, one must rely on animal studies for the toxicity information. Rather than delving into dose-response curves and lethal dose calculations,  a good MSDS writer,  will refer to published OSHA,  American Council of Governmental Industrial Hygienists (ACGIH), and National Institute of Occupational Safety and Health (NIOSH) exposure values for the compound because these numbers are based on a worker’s exposure to the chemical in an eight hour workday.   Clearly,  someone in charge of MSDS preparation could be a CHMM,  CIH, CSP, or PE with an extensive background in workplace environmental,  safety and hygiene principles.   In an effort to combat some of the quality problems with MSDSs,  the Chemical Manufacturers Association came up with a sixteen section voluntary MSDS format in 1993. The American National Standards Institute (ANSI) approved of this format and published standard Z400.1-1993  “American National Standard for Hazardous Industrial Chemicals — Material Safety Data Sheets — Preparation.”  The sixteen sections of an MSDS prescribed by the ANSI standard are as follows:  

1. Chemical Product & Company Information 
2. Composition/Information on Ingredients 
3. Hazards Identification   
4. First Aid Measures 
5. Fire Fighting Measures 
6. Accidental Release Measures 
7. Handling and Storage 
8. Exposure Controls/Personal Protection 
9. Physical and Chemical Properties 
10. Stability and Reactivity 
11. Toxicological Information 
12. Ecological Information    
13. Disposal Considerations   
14. Transport Information     
15. Regulatory Information    
16. Other Information               

             Although these standards were supposed to introduce a level of consistency in MSDSs,  OSHA has yet to amend the initial HCS.  As a chemical manufacturer,  it is recommended that the ANSI standard format be used for MSDSs because the information can be readily found in specific sections and employee training can be facilitated with consistent data sheets.  The ANSI standard is also recommended for those manufacturers who export their products overseas, because many nations rely on the format for their own compliance with local regulations.  It is important to remember that while the ANSI standard is a good format, it is only a recommended one,  and at a minimum, you must include all OSHA required information because the OSHA standard is legally enforceable. 

            Once a chemical manufacturer prepares the MSDS,  the ultimate responsibility for approval lies with the company’s director.  Any questions from a chemical user must be directed to officials at the company who are familiar with the contents of the MSDS.  OSHA does not offer any review services, even though the agency will issue citations and fines for incomplete or missing information.  A multi-disciplined approach using a company’s legal,  safety,  and other resources can ensure that compliance with the HCS is maintained. What can the chemical manufacturer do to avoid common pitfalls associated with MSDSs?  Review your current MSDS.  Does it at least meet the OSHA criteria for providing specific health and physical hazard information?  If you are unsure,  do you know where to go for updating the information?  If your in-house environmental, health, and safety resources are limited,  it may be wise to utilize the services of a consultant who is versed in the nuances of the regulations.