How to Know when a Safety Data Sheet is required

How to Know when a Safety Data Sheet is required

This question is often asked of our staff when talking with people at trade shows and other events that we attend throughout the year. With companies focusing more on safety and compliance in response to the OSHA Hazard Communication Standard (HCS) and unprecedented health concerns around COVID-19, we will cover this question in-depth to provide you with accurate information to keep yourself and others safe in your workplace.

What is a Safety Data Sheet?

A key component of a company’s written hazard communication program are Safety Data Sheets (SDSs), which are written or printed materials around hazardous chemicals prepared in accordance with the requirements in paragraph (g) of the Hazard Communication Standard

SDS have been used by chemical manufacturers for decades but it wasn’t until 2012, with the introduction of the Hazard Communication Standard, when safety data sheets were standardized in the Globally Harmonized System (GHS) format that is now used.

What is the Hazard Communication Standard?

Hazard Communication initiatives help to reduce chemical-related occupational illnesses and injuries by providing specific information that identifies and evaluates hazardous chemicals in the workplace. Tools such as Safety Data Sheets (SDS) and GHS container labels help employers identify and communicate these hazards in a standardized form.

What is the Globally Harmonized System?

The answer to this question is very detailed and quite extensive. In short, GHS was created for standardizing the classification and labeling of chemicals. It helps to define the physical and environmental hazards of a given chemical and communicate that information on labels and Safety Data Sheets (SDS) in an easy to follow format that is consistent for all chemical products. For a more comprehensive view of this system, check out OSHA’s Guide to GHS.

What defines a hazardous chemical or product?

The 2012 version of the HCS defines a hazardous chemical as one which is a physical hazard or a health hazard. 

Health Hazard Definitions

The HCS defines a health hazard as a chemical which is classified as posing one of the following hazardous effects:

  • Acute toxicity (any route of exposure)
    • The adverse effects resulting from a single exposure to a substance.
  • Skin corrosion or irritation
    • Corrosive materials are highly reactive substances that cause damage to living tissue while an irritant material causes a reversible inflammatory effect on living tissue by chemical reaction at the site of contact.
  • Serious eye damage or eye irritation
    • This one is pretty self-explanatory. Similar to corrosion or irritation of the skin.
  • Respiratory or skin sensitization
    • The respiratory system includes the organs used in breathing such as the nose, throat, larynx, trachea, bronchi, and lungs. Sensitization of the respiratory system or skin causes a substantial proportion of exposed people to develop an allergic reaction in normal tissue after repeated exposure to a chemical.
  • Germ cell mutagenicity
    • A mutagen is a substance that causes an increase in the rate of change in genes. These mutations can be passed along as the cell reproduces, sometimes leading to defective cells or cancer.
  • Carcinogenicity
    • A carcinogen is a substance that causes cancer. Carcinogenic material is one that is known to cause cancer. The process of forming cancer cells from normal cells is called carcinogenesis.
  • Reproductive toxicity
    • A reproductive toxin is a substance that can cause adverse effects on the reproductive system. The toxic effects may include alterations to the reproductive organs and/or the endocrine system. These effects can occur in both men and women.
  • Target organ toxicity (single or repeated exposure)
    • Target organ effects indicate which bodily organs are most likely to be affected by exposure to a substance. Most chemicals that produce systemic toxicity do not cause a similar degree of toxicity in all organs but usually produce the major toxicity to one or two organs. These are referred to as target organs of toxicity for that chemical.
  • Aspiration hazard
    • Aspiration is the entry of a liquid or solid chemical directly through the oral or nasal cavity, or indirectly from vomiting, into the trachea and lower respiratory system. Aspiration is initiated at the moment of inspiration, in the time required to take one breath, as the causative material lodges at the crossroad of the upper respiratory and digestive tracts in the laryngopharyngeal region.

Physical Hazard Definitions

The HCS defines a physical hazard as a chemical that is classified as posing one of the following hazardous effects:

  • Explosive
    • Explosive refers to a chemical compound or mixture that is capable of exploding.
  • Flammable (Gases, aerosols, liquids, or solids)
    • A flammable gas is defined as any material which is a gas at 20 oC (68 oF) or less and 101.3 kPa (14.7 psi) of pressure.
    • A flammable liquid is defined as any liquid having a flash point at or below 199.4 °F (93 °C).
    • A flammable solid is defined as a readily combustible solid, or which may cause or contribute to fire through friction.
  • Oxidizer
    • Oxidation reactions are usually very exothermic. Therefore, if a compound says “Oxidizer”, this means that it can cause other materials to combust more readily or make fires burn more fiercely.
  • Self-reactive
    • A self-reactive substance is a thermally unstable liquid or solid substance liable to undergo a strongly exothermic decomposition even without oxygen.
  • Pyrophoric (liquid or solid)
    • A pyrophoric material can spontaneously ignite in air. Many pyrophoric materials are also water reactive, reacting vigorously with water or high humidity, often igniting upon contact.
  • Organic peroxide
    • An organic peroxide is one that is carbon based and contains a peroxo unit. Peroxides can occur in virtually any kind of organic chemical, however, certain chemicals are particularly prone to peroxide formation and pose special hazards.
  • Corrosive to metal
    • Rust and electrochemical oxidation are forms of corrosion that occur on metals
      • These typically occur on a much slower time scale and 
      • These are not a health effect and, therefore, are not usually noted on an SDS except perhaps in storage recommendations. 
      • The U.S. Department of Transportation includes metal in their definitions.
  • Gas under pressure
    • Gases Under Pressure are gases which are contained in a receptacle (container) at a pressure of 200 kPa (kilopascals) or 29 psi (pounds square inch gauge) or more, or which are liquefied or liquefied and refrigerated. This includes compressed gases, liquefied gases, dissolved gases, and refrigerated liquefied gases.
  • Contact with water emits flammable gas
    • Water reactive substances are dangerous when wet because they undergo a chemical reaction with water. This reaction may release a gas that is either flammable or presents a toxic health hazard. In addition, the heat generated when water contacts such materials is often enough for the item to spontaneously combust or explode.
    • In simpler terms, water reactive materials are incompatible with water.

Is a safety data sheet required for consumer chemical products?

The answer to this question depends on a couple of factors. First, let’s remember that the OSHA Hazard Communication Standard (HCS) requires businesses to have SDS for all potentially hazardous chemicals present within the workplace. This can include items such as Windex, Lysol, and other basic cleaners. However, the key factor is the manner in which the chemical product is used will determine whether or not an SDS is required to be on-hand for a particular chemical product. 

Below are a couple of use-case examples:

Case #1 – An employee uses Windex to clean their office window once or twice per week. This would fall directly into the manufacturer’s suggested use guidelines and would thus be categorized as a consumer use of that product. In this specific case, you would not be required to provide a SDS.

Case #2 – The employee uses the same Windex product to continually clean all windows in the entire office throughout the workday. Because of the frequency of use, this would be categorized as a non-consumer use of the product. The employee, in this case, is exposed to a higher rate of the chemical and the employer would be required to provide the SDS for this product to the employees.

Conclusion

If your employees are using consumer chemical products in the same manner that is directed by the manufacturer, you shouldn’t need to worry about having a SDS on-hand. However, if your employees use consumer chemical products for purposes that extend beyond the manufacturer’s direction, especially in regards to the frequency and quantity of use, then their exposure rate is higher and you should supply SDS for those products.

Ultimately, it comes down to using common sense on this matter. It’s always better to have the SDS on-hand rather than not because OSHA will not penalize you for erring on the side of caution.We recommend referring to the OSHA Letter of Interpretation titled, “Requirements for maintaining safety data sheets for consumer art products and office cleaning products.”

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