Material Safety Data Sheets (MSDS)
The purpose of a Material Safety Data Sheet (MSDS) is to inform industrial purchasers and users of hazardous chemicals of the reasonably foreseeable physical and chemical hazards that may arise from the use of those chemicals. Most materials packaged for consumer use are exempt from the requirements of the Hazard Communication Standard (HCS). The MSDS should include precautions for normal use, handling, storage, disposal, and spill cleanup. It should not include recommendations for protective measures that are more strict than needed. OSHA states, in the inspection procedures for the HCS,10 "Some MSDSs include recommendations for protective measures that are for 'worst case scenarios,' e.g., recommending supplied air suits for products of relatively low toxicity. The HCS requires that accurate information be provided on the MSDSs. This applies as much to 'overwarning' on the MSDS and label as well as the absence of information ('underwarning')."
In the 1940s the Manufacturing Chemists' Association, now known as the Chemical Manufacturers Association (CMA), began producing "Chemical Safety Data Sheets" containing "Properties and Essential Information for Safe Handling and Use" of some of the more important hazardous chemicals used in commerce.
Ultimately about 100 of these Data Sheets were produced. They were very detailed in their coverage of each chemical, to the point of being almost a stand-alone book on the product. The longest Data Sheet was 46 pages. Later, some chemical companies began to produce data sheets for some of their high volume or hazardous chemicals. CMA no longer produces or supports the "Chemical Safety Data Sheets."
On November 25, 1983 OSHA published the Hazard Communication Standard as 29 CFR Part 1910, adding §1910.1200. This initial standard applied only to Standard Industrial Classification (SIC) Codes 20 through 39. The requirement that manufacturers and distributors provide MSDSs to their customers became effective on November 25, 1985. The standard does not require a particular format for the MSDS, but does specify what information must be included. Effective September 23, 1987, the requirements of the standard were extended to include "... all employers with employees exposed to hazardous chemicals in their workplaces."
In 1986 the U.S. Environmental Protection Agency (EPA) published the "Emergency Planning and Community Right-To-Know Act of 1986," and in 1988 "Toxic Chemical Release Reporting: Community Right-To-Know." The use and distribution of MSDSs is an important part of these regulations. The "Toxic Chemical Release Reporting" regulation requires that MSDSs for chemicals requiring reporting by these regulations contain specific language notifying users that these chemicals are subject to these regulations. These and other EPA regulations have been promulgated under Title III C Emergency Planning and Community Right-To-Know Act of the Superfund Amendments and Reauthorization Act of 1986 (EPCRA). OSHAs definition of a hazardous chemical is broad, and includes many materials that might otherwise be considered innocuous. Because of the potential for product liability suits, and the demands of customers for MSDSs for almost all materials they purchase, manufacturers usually prepare MSDSs for even relatively harmless materials.
OSHA requires manufacturers and importers of hazardous chemicals to distribute MSDSs with information concerning reasonably foreseeable health and toxicity concerns arising from their use. Users of these chemicals are required to ensure that these MSDSs are received with chemicals they purchase, and that they are used and available in the workplace.
Content of a MSDS
Paragraph (g) of the OSHA Hazard Communication Standard specifies what must be contained in MSDSs. OSHA publishes a form that can be used for the MSDS, but does not require its use, as long as all of the required information is included. A condensed version of the language in the standard follows. Chemical manufacturers and importers shall obtain or develop a Material Safety Data Sheet for each hazardous chemical they produce or import. Employers shall have a Material Safety Data Sheet in the workplace for each hazardous chemical they use.
Each MSDS shall be in English, and shall contain at least the following information:
- The identity (product name) used on the label, and chemical and common name(s) of ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition, except carcinogens shall be listed if the concentrations are 0.1% or greater; and,The chemical and common name(s) of all ingredients which have been determined to present a physical hazard when present in the mixture;
- Relevant physical and chemical characteristics of the hazardous chemical (such as vapor pressure, flash point);
- Relevant physical hazards, including the potential for fire, explosion, and reactivity;
- Relevant health hazards, including signs and symptoms of exposure, and any medical conditions generally recognized as being aggravated by exposure to the chemical;
- The primary route(s) of entry into the body;
- The OSHA permissible exposure limit and ACGIH Threshold Limit Value. Additional applicable exposure limits may be listed;
- Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Annual Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions), or by OSHA;
- Precautions for safe handling and use, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks;
- Appropriate control measures, such as engineering controls, work practices, or personal protective equipment;
- Emergency and first aid procedures;
- The date of preparation of the MSDS or the last change to it; and,
- The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the MSDS, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.
If no relevant information is found for any given category, it should be marked to indicate that no applicable information was found.
If significant new information becomes available regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the MSDS within three months.
A MSDS must be provided with the initial shipment of a hazardous chemical, and with the first shipment after a MSDS is updated.
MSDSs shall also be made readily available, upon request, to designated employee representatives and to OSHA representatives.
This reference was compiled from a number of sources, and is intended to be a concise, relatively non-technical source of information on the subject of MSDSs.