2.3 Safety Data Sheets (SDS) and OSHA Hazard Communication

Safety Data Sheets (SDS) and OSHA Hazard Communication

Introduction to Safety Data Sheets (SDS)

While the pesticide label serves as the primary legal guide for pesticide application, the Safety Data Sheet (SDS) is a separate, comprehensive document that provides detailed information regarding the chemical and physical hazards of a product. Formerly known as Material Safety Data Sheets (MSDS), SDSs are regulated by the Occupational Safety and Health Administration (OSHA) under the Hazard Communication Standard (HCS). This standard is aligned with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), which establishes a standardized, 16-section format for chemical safety information worldwide.

Key Differences: Label vs. SDS

It is essential for pesticide applicators to distinguish between the pesticide label and the SDS:

• Pesticide Label (EPA / FIFRA):
  • Approved by the U.S. EPA under the authority of FIFRA.
  • A legally binding document; deviation from its instructions is a violation of federal and state law.
  • Focuses on the specific instructions for pesticide use, including application rates, target sites, crops, pest species, environmental precautions, and Restricted Entry Intervals (REI).
• Safety Data Sheet (OSHA / GHS):
  • Regulated by OSHA to protect workers in occupational settings.
  • Not a pesticide application guide; it does not contain crop-specific application rates or specific target pest lists.
  • Focuses on bulk storage, chemical manufacturing, transportation safety (DOT regulations), emergency spill response, firefighting, and occupational exposure limits for employees.

The 16 Standardized SDS Sections

The GHS mandates that every SDS must display chemical safety information across 16 standard sections in a specific sequence:

1. Identification: Product name, manufacturer/distributor contact information, emergency telephone numbers, and recommended chemical uses.
2. Hazard(s) Identification: Chemical classifications (e.g., flammable liquid, skin irritant), GHS signal words (Danger or Warning), hazard statements, precautionary statements, and hazard pictograms.
3. Composition/Information on Ingredients: Chemical names, common synonyms, Chemical Abstracts Service (CAS) numbers, and concentrations of active and hazardous inert ingredients.
4. First-Aid Measures: Necessary first-aid actions based on the route of exposure (inhalation, ingestion, skin, eye contact), description of immediate and delayed symptoms, and recommendations for special medical treatment.
5. Fire-Fighting Measures: Suitable and unsuitable extinguishing media, specific chemical hazards resulting from combustion (such as toxic gases), and specialized protective equipment and precautions for firefighters.
6. Accidental Release Measures: Personal safety precautions, required protective equipment, environmental protections, and methods for containing and cleaning up chemical spills or leaks.
7. Handling and Storage: Safe handling procedures (to minimize exposure) and guidelines for secure storage, including ventilation requirements and chemical incompatibilities.
8. Exposure Controls/Personal Protection: Occupational exposure limits, including OSHA Permissible Exposure Limits (PELs) and ACGIH Threshold Limit Values (TLVs), engineering controls (such as ventilation systems), and required personal protective equipment (PPE).
9. Physical and Chemical Properties: Technical details including physical state, color, odor, pH, boiling/melting points, flash point, flammability, vapor pressure, relative density, and water solubility.
10. Stability and Reactivity: Chemical stability, reactivity hazards, conditions to avoid (such as extreme heat), incompatible materials, and hazardous decomposition products.
11. Toxicological Information: Likely routes of exposure, short-term and long-term exposure symptoms, acute toxicity values (such as oral, dermal, and inhalation LD50 or LC50), and potential carcinogenicity or reproductive toxicity.
12. Ecological Information: Ecotoxicity to aquatic and terrestrial organisms, persistence and degradability in the environment, bioaccumulative potential, and soil mobility.
13. Disposal Considerations: Safe methods for disposing of chemical wastes, surplus chemicals, and contaminated packaging, in compliance with environmental regulations.
14. Transport Information: Department of Transportation (DOT) shipping requirements, including United Nations (UN) numbers, proper shipping names, hazard classes, and packaging groups.
15. Regulatory Information: Safety, health, and environmental regulations specific to the product (such as SARA Title III reporting or state chemical registries).
16. Other Information: Date of SDS preparation, last revision date, and a key explaining abbreviations or classifications.

OSHA Employer Requirements

Under OSHA's Hazard Communication Standard, employers are legally required to keep SDSs for all hazardous chemicals—including pesticides—used in their workplace. These sheets must be readily accessible to all employees who handle or may be exposed to the chemicals during their work shifts.

Accessibility means that workers must be able to view the SDSs instantly without barriers. If SDSs are stored on a computer, employees must know how to operate the system, and the database must not be password-protected or restricted. If they are kept in a physical binder, that binder cannot be locked in an office to which employees do not have a key. Employers must also provide training to all workers on how to read and interpret both pesticide labels and SDSs, and what safety precautions to follow.

When to Use the SDS vs. the Label

A common exam trap asks the applicator to find an application rate in the SDS — the answer is the label, never the SDS. The reverse trap asks where to find an OSHA PEL — the answer is the SDS Section 8, never the label.