3.2 Safety Data Sheets (SDS) & Container Labeling

One of the most significant changes introduced by the alignment of the Hazard Communication Standard (HCS) with the Globally Harmonized System (GHS) was the standardization of Safety Data Sheets (SDSs), formerly known as Material Safety Data Sheets (MSDSs). Under GHS, all SDSs must follow a strict, 16-section format, presented in a specific order. This layout ensures that emergency responders, employers, and employees can locate critical safety information rapidly during an incident.

The 16 sections are structured as follows:

1. Identification: Includes the product identifier, manufacturer or distributor name, address, phone number, emergency phone number, recommended use, and restrictions on use.
2. Hazard(s) Identification: Identifies the GHS hazards of the chemical, including the appropriate signal word, hazard statements, precautionary statements, pictograms, and any hazards not otherwise classified.
3. Composition/Information on Ingredients: Details the chemical name, common name/synonyms, CAS number, and concentration percentages of all ingredients in mixtures.
4. First-Aid Measures: Describes necessary first-aid instructions based on routes of exposure (inhalation, skin, eye contact, and ingestion), as well as important symptoms and effects (acute or delayed) and required immediate medical attention.
5. Fire-Fighting Measures: Specifies suitable and unsuitable extinguishing media, specific hazards arising from the chemical (such as toxic combustion gases), and protective equipment and precautions for firefighters.
6. Accidental Release Measures: Outlines personal precautions, protective equipment, emergency procedures, and methods for containment and clean-up of spills or leaks.
7. Handling and Storage: Details precautions for safe handling, including incompatible chemicals, and conditions for safe storage, including ventilation and temperature requirements.
8. Exposure Controls/Personal Protection: Lists exposure limits (OSHA PELs, ACGIH TLVs, NIOSH RELs), appropriate engineering controls, and recommended personal protective equipment (PPE).
9. Physical and Chemical Properties: Identifies the chemical’s physical state, appearance, odor, pH, melting point, boiling point, flashpoint, evaporation rate, flammability, vapor pressure, vapor density, relative density, and solubility.
10. Stability and Reactivity: Describes chemical stability, possibility of hazardous reactions, conditions to avoid (e.g., static discharge, vibration), incompatible materials, and hazardous decomposition products.
11. Toxicological Information: Identifies routes of exposure, symptoms of exposure, acute and chronic effects, and numerical measures of toxicity (such as LD50 values).
12. Ecological Information: Evaluates environmental impact, ecotoxicity, persistence, bioaccumulative potential, and mobility in soil (not enforced by OSHA but required for completeness).
13. Disposal Considerations: Describes safe disposal methods, recycling, and container disposal practices (not enforced by OSHA).
14. Transport Information: Provides UN number, proper shipping name, hazard class, and packing group for shipping (not enforced by OSHA).
15. Regulatory Information: Lists federal, state, or international regulations governing the chemical (not enforced by OSHA).
16. Other Information: Indicates when the SDS was prepared or last revised, and other useful notes.

Note that while OSHA requires sections 12 through 15 to be present in the SDS to maintain alignment with the UN GHS, the agency does not enforce their content because they fall under the jurisdiction of other federal agencies, such as the Environmental Protection Agency (EPA) and the Department of Transportation (DOT).

Focus on Section 8: Exposure Controls and PPE

Section 8 is of paramount importance for industrial hygienists and safety professionals. It acts as the bridge between chemical evaluation and practical workplace control measures.

• Exposure Limits: This section must specify the OSHA Permissible Exposure Limits (PELs), ACGIH Threshold Limit Values (TLVs), and any other recommended exposure limits. These limits dictate the maximum concentration of a chemical to which a worker may be exposed over a specific timeframe.
• Engineering Controls: The SDS must detail the engineering controls required to keep airborne concentrations below exposure limits. This includes local exhaust ventilation, general dilution ventilation, process enclosure, or isolation of the operation.
• Personal Protective Equipment (PPE): The SDS must prescribe specific PPE based on the hazards. Rather than general statements like "wear gloves," it must specify the material (e.g., nitrile, neoprene, or butyl rubber gloves) and the type of eye protection (e.g., splash-resistant goggles or face shield). For respiratory protection, it must list the required respirator type (e.g., half-face organic vapor respirator or supplied-air respirator) and the specific cartridges (e.g., N95, HEPA, or acid gas cartridges) based on concentration levels.

Labeling Requirements: The Six Core Elements

Under the HCS, every container of hazardous chemicals entering or leaving a workplace must be labeled with a primary label containing six mandatory elements:

1. Product Identifier: The unique name or number used to identify the chemical, which must match the identifier on the SDS and chemical inventory.
2. Signal Word: A single word used to indicate the relative level of severity of the hazard.
   • Danger: Used for more severe hazards (e.g., high toxicity, extreme flammability).
   • Warning: Used for less severe hazards. Only one signal word is permitted on a label. If a chemical has multiple hazards that warrant both "Danger" and "Warning," only "Danger" will appear.
3. Hazard Statements: Standardized phrases assigned to a hazard class and category that describe the nature of the hazards, including, where appropriate, the degree of hazard (e.g., "Causes damage to organs through prolonged or repeated exposure" or "Highly flammable liquid and vapor").
4. Precautionary Statements: Standardized phrases describing recommended measures to minimize or prevent adverse effects resulting from exposure, improper storage, or handling. They cover four areas: Prevention, Response (first aid/spill response), Storage, and Disposal.
5. Pictograms: Graphic symbols used to communicate specific hazard information. There are 9 GHS pictograms, each consisting of a black symbol on a white background framed by a red diamond border.
   • Flame: Flammables, pyrophorics, self-heating, emits flammable gas, self-reactives, organic peroxides.
   • Flame over Circle: Oxidizers.
   • Corrosion: Skin corrosion/burns, eye damage, corrosive to metals.
   • Gas Cylinder: Gases under pressure.
   • Exploding Bomb: Explosives, self-reactives, organic peroxides.
   • Skull and Crossbones: Acute toxicity (fatal or toxic).
   • Health Hazard: Carcinogens, mutagens, reproductive toxicity, respiratory sensitizers, target organ toxicity, aspiration toxicity.
   • Exclamation Mark: Irritant (skin/eye), skin sensitizer, acute toxicity (harmful), narcotic effects, respiratory tract irritant, hazardous to ozone layer (non-mandatory).
   • Environment: Aquatic toxicity (non-mandatory, enforced by EPA).
6. Supplier Identification: Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

Portable Container Exemptions

Under 29 CFR 1910.1200(f)(8), employers are not required to label portable containers into which hazardous chemicals are transferred from labeled containers, provided that:

1. The chemical is transferred for the immediate use of the employee who performs the transfer.
2. The employee uses the chemical only during their own work shift.
3. Any remaining chemical is returned to a labeled container or properly disposed of at the end of the shift.

If another employee uses the container, or if it is left unattended past the shift, it must be labeled with the product identifier and general hazard warnings.