Material Safety Data Sheets, MSDS

Learning Goals:

  1. Understand the uses and limitations of SDS and MSDS sheets

A very important OSHA regulation is the Hazard Communication Standard. It requires employers to notify employees about the nature of hazardous chemicals they encounter during their work. The employer must provide proper training, as well. From the simple concept of notification springs many details: how big the warning signs must be, how much chemical one can transfer into a new container before the new container must be labeled, and lots of other details that we won't get into. One very important part of the "Haz Comm" regulation is the requirement for the producers of chemicals to provide notification through their chain of delivery of the risks involved with transport, use, or spillage of the chemical. This required notification is known as a Material Safety Data Sheet, or MSDS. (We often use the term "MSDS sheets" even though it is redundant.)

Now while the term "MSDS" is still very common, in 2012 OSHA wanted to align the US regulations with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and updated the regulations and the corresponding information sheets. These are now known as SDS, Safety Data Sheets. While the authors of the MSDS had some leeway as to form, the new SDS format is quite prescriptive. Here are the 16 required sections of the GHS form:

Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.

Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.

Section 4, First-aid measures includes important symptoms/effects, acute, delayed; required treatment.

Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.

Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.

Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.

Section 8, Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); ACGIH Threshold Limit Values (TLVs); and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the SDS where available as well as appropriate engineering controls; personal protective equipment (PPE).

Section 9, Physical and chemical properties lists the chemical's characteristics.

Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.

Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

Section 12, Ecological information*
Section 13, Disposal considerations*
Section 14, Transport information*
Section 15, Regulatory information*

For more details on what is needed in each section, see this section from the original regulation. Note that ANSI has a similar 16 part MSDS format and often diligent chemical manufactures and suppliers used that ANSI format, so the changeover to the GHS format would be slight.

Today, there is not much difference between the GHS SDS and an ANSI standard MSDS. Employers and suppliers of chemicals have been changing their records, and this year, 2016, are supposed to be 100% GHS compliant, that is, have all their MSDS sheets in the SDS format. As you cruise around looking for material, you will still find many MSDS sheets in the old form.

Either form, there are some good and bad points about MSDS sheets.

First the good. MSDS sheets are readily available. (I'll give you some sources in a minute.) You can, with a click or two, get lots of basic information, such as physical and chemical properties and toxicological information. When considering a chemical I am not familiar with, I frequently go to readily available MSDS sheets to learn some more about it. The CAS is very handy if I want to search some more.

Now the bad. OSHA did not require the chemical manufacturer to test anything regarding their chemicals. If information was published and available, the manufacturers had to report that, but they did not and do not have to test anything. They can quite legally put "not known" for almost any property, if they in fact do not know. For our concern in hazardous waste, many chemicals are not manufactured, a combustion byproduct for example, or not in use. So there is no "manufacturer" of the chemical. Often such chemicals are available from laboratory supply companies who do put out an MSDS, but it is only for the solution that the laboratory makes, which may be a specialized solution. While the large chemical manufacturers are very diligent about their safety programs, many smaller firms and importers are not. But not always. Remember Dr. Karen Wetterhahn back in Submodule 1D . Review her case, then look up this MSDS sheet on the chemical that killed her, dimethyl mercury. Here is the MSDS that was probably the one she would have used. For the homework, this is the one we will assume she used.

Some quiz questions:
What was the actual exposure route into Wetterhahn?
What was she doing to protect herself?
This MSDS sheet is found on whose website?
This MSDS sheet was written by the manufacturer - what is their name?
What warning does the MSDS sheet give that would have helped Wetterhahn?

But now we'll note some differences between MSDS for that same chemcial. Go to Course Documents and look at "old MSDS for DMM" and "new MSDS for DMM." Now here is something from the same lab. DMM Update so the lab has augmented its notices with updates about toxicity of DMM, but the linked MSDS sheet is the same old sheet.

Here is a great site for MSDS and other data. University of Vermont's Safety Information Resources Incorporated. Vermont SIRI . You'll see it has different hyperlinks for MSDS sheets. Those are search engines, each that return sheets from several sources.

Next, MSDS Homework

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