MSDS requirements

A similar report is required of any facility with MSDS requirements under OSHA for hazardous chemicals. It must submit one of two different emergency and hazardous chemical inventory forms. Tier I provides aggregate information on each hazardous chemical with the type of health and physical hazards it presents and the estimates of daily quantities at the facility (maximum and average daily amounts). Tier II is the most complete report and contains all information provided in Tier I. It is commonly preferred by government agencies and includes chemical-specific information, such as the following ... 

In the United States, MSDSs originated in the shipbuilding industry using a format designated as the US Department of Labor, Occupational Safety Health Administration (OSHA) Form 20. Chemical manufacturers expanded the original 2-page OSHA Form 20 in order to more adequately provide health and safety data on chemical products. Under the OSHA Hazard Communication Standard (29 Code of Federal Regulations (CFR) 1910.1200) issued in 1983, MSDS requirements are performance oriented and do not require a specific format. However, there is a nonmandatory OSHA Form 174. 

These properties can be found in standard references [1, 2,3] and iri the Material Safety Data Sheets (MSDS) required for all hazardous substances and available from suppliers. Figure 2-1 shows an MSDS formwith the information requirements contained in OSHA 29 CFR 1910.1200(g). Many companies use the more comprehensive ANSI Standard 2400.1, Preparation of Material Safety Data sheets, which may run 8-12 pages in length. If the material is a specialty product manufactiued on site, the properties must be determined and documented by the plant owner. 

The hazards associated with handling pigments is contained ia the MSDS mandated by an OSHA Hazards Communication Standard (28) which also requires labeling and employee information and training. 

Table 2 Hsts some of the physical, toxicity, flammabiUty, and reactivity properties of common chemicals (10,13,42,45—51). Also given are some of the quantities specified for reporting spills and for compliance with legislated requirements. The OSHA regulations require that material safety data sheets (MSDS) be developed for all process materials, so that the ha2ard data can be communicated to employees (52). Characteristics of toxicity, flammabiUty, chemical iastabiUty, reactivity and reaction energy, operatiag coaditioas, and corrosive properties of constmction materials must all be considered ia analy2iag ha2ard poteatials of chemicals and chemical operations.

MSDS summarizes all of the important health, safety, and environmental information about a substance. A version of this standard also appHes to laboratories, including research and development faciUties, and requires the development of a laboratory hygiene plan. 

Isocyanates. Isocyanates in general are toxic chemicals and require great care in handling. Oral ingestion of substantial quantities of isocyanates can be tolerated by the human body, but acute symptoms may develop from the inhalation of much smaller amounts. The inhalation of isocyanates presents a ha2ard for the people who work with them as weU as the people who Hve in the proximity of an isocyanate plant. Adequate control of exposure is necessary to achieve a safe working environment. The suppHers Material Safety Data Sheets (MSDS) have to be consulted for the most current information on the safe handling of isocyanates. 

The toxicology, occupational health hazards, and transportation regulations of cesium compounds result from the anion rather than the cesium cation. Producers and distributors provide an MSDS as well as detailed shipping requirements for each product. 

CAS Number - Chemical Abstracts Service Registry Number A CAS (Chemical Abstracts Service) Registry Number is a unique identifier that tells you, for example, that aeetone and dimethyl ketone are actually the same substance. The Chemical Abstracts Service is a division of the American Chemical Society. OSHA only requires certain items on an MSDS and a CAS number is not one of them. However, authors of MSDS s are allowed to add additional information, such as the CAS number, if they desire. The numbers you see on trucks on the highway are not CAS Numbers, butU.S. Department of Transportation (DOT) codes, which are not necessarily specific to each chemical. Their aim is to assist emergency responders. 

Cutaneous Cutaneous relates to or affects the skin. The term subcutaneous refers to being below the skin (as in a penetrating injury or injection). Use your MSDS to determine the required personal protective equipment (PPE) that you must use. Protecting the skin (with gloves, aprons, coveralls, face masks, etc.) is important. After all, the skin is the largest organ in the human body. 

De Minimis Limitation. A listed toxic chemical does not have to be considered if it Is present in a mixture at a concentration below a specified de nvnimis level. The de minimis level is 1.0%, or 0.1% if the chemical meets the OSHA carcinogen standard. See Table II for the de minimis value associated with each listed toxic chemical. For mixtures that contain more than one member of a listed chemical category, the de minimis level applies to the aggregate concentration of all such members and not to each individually. EPA included the de minimis exemption In the njle as a burden reducing step, primarily because facilities are not likely to have information on the presence of a chemical in a mixture or trade name product beyond that available in the product s MSDS. The de minimis levels are consistent with OSHA requirements lor development of MSDS information concerning composition. 

Supplier Notification. In 1989 and subsequent years, suppliers of facilities in SIC codes 20-39 are required to develop and distribute a notice if the mixtures or trade name products that they manufacture or process, and subsequently distribute, contain listed toxic chemicals. These notices are distributed to other companies in SIC codes 20-39 or to companies that sell the product to facilities in SIC codes 20-39. tf a Material Safety Data Sheet (MSDS) is not required for the mixture or trade name product, the notification must be in written form (i.e., letter or attachment to a MSDS). Otherwise, the notice must be incorporated into or attached to the MSDS for that product. The supplier notification requirement began with the first shipment of a product in 1989 and must accompany the first shipment each year thereafter. In addition, a new or revised notice must be sent if a change occurs in the product which affects the weight percent of a listed chemical or if it is discovered that a previous notice did not property identify the chemicals or the percentage by weight. For more information on supplier notification, see Appendix E. 

The required notification must be provided at ieast annually In writing. Acceptable forms of notice are, for example, a letter, product labeling, and product literature distributed to customers. If you are required to prepare and distribute a Material Safety Data Sheet (MSDS) for the mixture under the Occupational Safety and Health Act (OSHA) Hazard Communication Standard, your section 313 notification may be attached to the MSDS or the MSDS may be modified to include the required information. (A sample letter and recommended text for inclusion in an MSDS appear on pages E-4 and E-5 of this appendix.)... 

You must make it clear to your customers that any copies or redistribution of the MSDS or other form of notification must include the section 313 notice. Inotherwords, yourcustomers should understand their requirement to include the section 313 notification if they give your MSDS to their customers. 

In general, you must notify each customer receiving a mixture or trade name product containing a listed toxic chemical with the first shipment of each calendar year. You may send the notice with subsequent shipments as well, but it is required that you send it with the first shipment each year. Once customers have been provided with an MSDS containing the section 313 information, you may refer to the MSDS by a written letter in subsequent years (as long as the MSDS is current). 

Software manages and tracks MSDS database information by chemical ID, supplier, synonyms, components, registry numbers, completion status, uses, and hazard classes. Subscription updating. Requires 640K memory and hard disk. 

MSDS Material Safety Data Sheet - a document that provides pertinent information and a profile of a particular hazardous substance or mixture. An MSDS is normally developed by the manufacturer or formulator of the hazardous substance or mixture. The MSDS is required to be made available to employees and operators whenever there is the likelihood of the hazardous substance or mixture being introduced into the workplace. Some manufacturers prepare MSDS for products that are not considered to be hazardous to show that the product or substance is not hazardous. 

According to EPCRA, facilities should provide either an MSDS or a list of chemicals to the SERC, LEPC, and local fire department. If facilities choose to supply only a list, the list should include specific information including health hazards, fire hazards, reactivity hazards, and physical data for every chemical on the list. Although only a list is required, the additional requirements for specific information makes the submission of only a list a rare occurrence. The use of MSD sheets is one of the most commonly used tools to convey this information. 

The information to be compiled about the chemicals, including process intermediates, needs to be comprehensive enough for an accurate assessment of the fire and explosion characteristics, reactivity hazards, the safety and health hazards to workers, and the corrosion and erosion effects on the process equipment and monitoring tools. Current material safety data sheet (MSDS) information can be used to help meet this requirement but must be supplemented with process chemistry information, including runaway reaction and over-pressure hazards, if applicable. 

In line with The Occupational Safety and Healtli Administration (OSHA) requirements, employers must maintain a complete and accurate MSDS... 

While MSDS s arc not required to be physically attached to a shipment, they must accompany or precede Oic shipment. When tlie manufacturer/supplicr fails to send an MSDS with a sliipmcnt labeled as a liazardous chemical, the employer must obtain one from Oie chemical manufacturer, importer, or distributor as soon as possible. Similarly, if the MSDS is incomplete or unclear, the employer should contact the manufacturer or importer to get clarification or obtain missing information. 

It is important to note that OSHA specifics the information to be included on an MSDS, but docs not prescribe the precise format for an MSDS. A non-mandatory MSDS form that meets the Hazard Communication StancLird requirements has been issued and can be used as is or c.xpandcd as needed. The MSDS must be in English and must include at least Oie following information presented in Table 10.5.1, In reviewing this material, Uie reader should understand tlic effect and importance of each subsection in helping to identify a chemical hazard, particularly tlie section on healtli hazards. 

The sttuidard requires the prepmer of the MSDS to list atiy gcticrally applicable cotitrol tncasures. These include engineering controls, safe handling procedures, and personal protective equipment. Infonnation is often included on the use of goggles, gloves, body suits, respirators, and face shields. 

Search MSDS on CCINFOWeb. All databases on CCINFOWeb may be searched for free. The MSDSs are contributed by North American sources, many that are multi-national companies marketing chemical products worldwide. This database meets a growing international requirement for health and safety information on specific chemical products. It helps thousands of users worldwide manage their responsibilities under workplace, environmental and other right-to-know legislation. The MSDS database can be searched quickly and easily for product names and other product identifications, manufacturer or supplier names, dates of MSDSs, or any term used in the text of the MSDS itself. 

What this illustrates is that an MSDS describes the dangers of large industrial quantities of a substance, not the tiny amounts usually found in consumer products. Nonetheless, once you are experienced at reading an MSDS, it is a good place to get information on the safety of a chemical compound. In this book I cover safety issues only occasionally—and briefly. To do a more thorough job of that would require a much larger book, and there is already a wealth of information available. 

The advantages to using MSDSs for chemical inventories are that MSDSs are publicly available and required by law. There is no extra cost or labour needed to supply them. The limitations to using MSDSs as a source of inventory data are that currently, in the United States, a standardized reporting format is not mandatory. MSDSs are not verified or audited and MSDS information can be incomplete and/or inaccurate. In addition, OSHA s definition of hazard does not include the broader scope of hazard used in green chemistry. Therefore, chemicals that are potential hazards from the green chemistry perspective but are not defined by OSHA as hazards, are not required to be identified on a MSDS. 

MSDS Management Service is designed to help you manage your occupational health and safety responsibilities relating to MSDSs and WHMIS requirements. 

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