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EMP Guidance Manual Aspect 1: SDS/Labeling-ENV

Environmental Aspect 1:

SDS/Labeling

1.0  SAFETY DATA SHEETS (SDS)/Labeling

Under a federal regulation on hazardous material information communication (a law commonly referred to as HazCom), there are specific requirements for the distribution and use of certain chemicals/materials used in the workplace. A few of these topics will be addressed below. In 2012, the Occupational Safety and Health Administration announced changes to the Hazard Communication Standard to bring the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). These changes are being phased in over the next four years. Your facility Safety Manager or the Safety Department can provide specific information on HazCom, and provide guidance on the regulatory changes being implemented. Employees will be trained on the new label elements and the new Safety Data Sheets (SDSs) before December 1, 2013. Consult the Safety Management System (SMS) website for the document on the Hazard Communication Program (Document SMS-0043) for additional information or consult with your Safety Manager or Safety Specialist for assistance.

1.1  SDS

A primary concept of HazCom is that manufacturers and importers of hazardous material must do the following:

  • Evaluate the physical or health hazards associated with the chemicals/materials they produce;
  • Publish this information in a detailed technical bulletin called a safety data sheet or SDS (formerly called a material safety data sheet, or MSDS); and
  • Provide their customers with an SDS for each chemical/material they supply.

Company employees should NOT receive or use any chemical at their facility until an SDS has been obtained from the manufacturer or vendor and each one has been reviewed.

Under HazCom, a hazard is a chemical or material that is harmful to human health. These include chemicals or materials that pose a physical hazard because they are one or more of the following:

Flammable Reactive or corrosive Spontaneously ignitable Explosive

Chemicals or materials that pose a health hazard (e.g., cause cancer) also need to have an SDS under HazCom.

1.2  Components of an SDS

Under the GHS, information on Safety Data Sheets is being standardized. During the transition period, facility personnel will likely see a mixture of MSDSs under the existing system as well as SDSs under the GHS.

Under the existing system, manufacturers are not required to follow a standard format when developing their MSDSs; however, each MSDS must include the following sections and information:

  • Product and company identification: The material’s name and the manufacturer’s name and contact information.
  • Hazardous constituents: The chemical and common names of all the hazardous components and the maximum occupational exposure limits.
  • Physical and chemical characteristics: Material characteristics such as boiling point, vapor pressure, density, specific gravity, storage state, appearance and odor.
  • Fire and explosion hazard data: The material’s flashpoint (the lowest temperature at which a liquid gives off enough vapors that when mixed with air, it can be easily ignited by a spark).
  • Reactivity data: Description of the material’s tendency to chemically change or break down and become more dangerous. This section would also include conditions (i.e., light or heat) that might trigger reactive events and other materials to avoid putting in contact with this material.
  • Health hazard data: Description of possible routes of entry, acute and chronic health effects from exposure, signs and symptoms of exposure, and emergency and first aid procedures.
  • Precautions for safe handling and use: Recommended procedures to manage a spill or leak of the material and properly dispose of clean-up materials.
  • Control measures: Recommended procedures for proper ventilation and personal protective equipment (PPE) required for normal working conditions.

Some chemical manufacturers provide additional information on their MSDSs such as toxicological data and United States Department of Transportation (USDOT) shipping instructions.

Under the GHS, Safety Data Sheets must contain specific sections to ensure consistency in the presentation of important information. These sections include eleven mandatory and five non-mandatory sections as follows:

  • Section 1: Identification
  • Section 2: Hazard 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 (non-mandatory)
  • Section 13: Disposal Considerations (non-mandatory)
  • Section 14: Transport Information (non-mandatory)
  • Section 15: Regulatory Information (non-mandatory)
  • Section 16: Other Information (non-mandatory)

To comply with applicable environmental regulations, facility personnel should be aware of the hazards associated with chemical constituents in the materials they are using, especially when and how the material will be disposed. Also, facility personnel should understand all the precautions for safe handling and use of the chemicals/materials so that any accidental spills or releases are cleaned up properly.

1.3  Examples of Chemicals/Materials Requiring SDS

Examples of chemicals/materials commonly used in our facilities that require an SDS include:

  • Solvents (e.g., parts and brake cleaners);
  • Inks;
  • Acids and caustics;
  • Oils, lubricants and greases;
  • Vehicle fluids (e.g., windshield washer fluid and antifreeze);
  • Fuels (e.g., gasoline and diesel fuel); and
  • Paints and coatings.

SDSs may be kept in hard copy form (a three-ring binder) or electronically (a computer or through a third-party vendor using a computer or computer/fax system). It is critical that all employees are able to quickly access applicable SDSs within their work area(s) to allow rapid response to spills and/or employee exposure.

1.4  Labeling

Another requirement under HazCom is that containers holding a chemical/material that poses a physical or health hazard must be properly labeled. Under the current system, labels should match the MSDS for the material and must include the following information:

  • Product name/identification;
  • Name and address of the manufacturer or supplier;
  • A brief description of any physical and health hazards;
  • Precautions for safe handling and use; and
  • Control measures.

Under the GHS, information on labels is being standardized. After June 1, 2015, all labels will be required to have pictograms, a signal word, hazard and precautionary statements, the product identifier, and supplier identification. A sample revised HCS label, identifying the required label elements, is shown below. Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. During the transition period, facility personnel will likely see a mixture of chemicals labeled under the existing system as well as the GHS.

Labels on hazardous chemical/material containers should never be removed. If a label becomes worn, the container should be re-labeled using a permanent marker with all of the information mentioned above. Also, if a hazardous chemical/material is transferred into a new container and is not used up immediately, the secondary container must be labeled with the information described above, as well as the date and time the decant or mixture was transferred to the new container.

1.5  Labeling for Hazardous Materials Transportation

The transportation of hazardous materials is regulated by the US Department of Transportation (DOT) under Title 49 of the Code of Federal Regulations, Parts 106-180. Training is required for those individuals involved in transporting hazardous materials, and includes anyone who:

  • Prepares hazardous material for shipping;
  • Marks containers, drums, or packaging;
  • Loads or unloads hazardous materials (including forklift operators);
  • Operates a vehicle to transport hazardous material; or
  • Responds to emergencies.

Training on hazardous material transportation, including labeling and related issues is conducted by the Company Safety Department. Consult the Safety SMS for additional information, which can be found under Hazardous Material Transportation (SMS-0044).

Placards are ID numbers and hazard labels placed on tankers and trailers carrying hazardous materials. The shipper is responsible for offering proper placards to the driver and ensuring that placards are properly placed. Placards and labels must be visible and not obscured by other signage, markings, or other cargo.

Document # : WA-08830 / For Internal Use Only
Reference EtQ for the latest Revision / Effective Date: 2013-07-11
Revision # : 1 / Page 2 of 7

Classified - Internal use