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OSHA's MSDS
Requirements from 29 CFR 1910.1200: Hazard Communication
Each material safety data
sheet shall be in English (although the employer may maintain
copies in other languages as well), and shall contain at least
the following information:
The identity used on the label, and, except as provided for in
paragraph (i) of this section on trade secrets:
If the hazardous chemical is a single substance, its chemical
and common name(s);
If the hazardous chemical is a mixture which has been tested
as a whole to determine its hazards, the chemical and common
name(s) of the ingredients which contribute to these known hazards,
and the common name(s) of the mixture itself; or,
If the hazardous chemical is a mixture which has not been tested
as a whole:
The chemical and common name(s) of all ingredients which have
been determined to be health hazards, and which comprise 1% or
greater of the composition, except that chemicals identified
as carcinogens under paragraph (d) of this section 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 be health hazards, and which comprise less
than 1% (0.1% for carcinogens) of the mixture, if there is evidence
that the ingredient(s) could be released from the mixture in
concentrations which would exceed an established OSHA permissible
exposure limit or ACGIH Threshold Limit Value, or could present
a health risk to employees; and,
The chemical and common name(s) of all ingredients which have
been determined to present a physical hazard when present in
the mixture;
Physical and chemical characteristics of the hazardous chemical
(such as vapor pressure, flash point);
The physical hazards of the hazardous chemical, including the
potential for fire, explosion, and reactivity;
The health hazards of the hazardous chemical, including signs
and symptoms of exposure, and any medical conditions which are
generally recognized as being aggravated by exposure to the chemical;
The primary route(s) of entry;
The OSHA permissible exposure limit, ACGIH Threshold Limit Value,
and any other exposure limit used or recommended by the chemical
manufacturer, importer, or employer preparing the material safety
data sheet, where available;
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;
Any generally applicable precautions for safe handling and use
which are known to the chemical manufacturer, importer or employer
preparing the material safety data sheet, including appropriate
hygienic practices, protective measures during repair and maintenance
of contaminated equipment, and procedures for clean-up of spills
and leaks;
Any generally applicable control measures which are known to
the chemical manufacturer, importer or employer preparing the
material safety data sheet, such as appropriate engineering controls,
work practices, or personal protective equipment;
Emergency and first aid procedures;
The date of preparation of the material safety data sheet 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 material safety data sheet, 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 on
the material safety data sheet, the chemical manufacturer, importer
or employer preparing the material safety data sheet shall mark
it to indicate that no applicable information was found.
Chemical manufacturers and
importers are required to obtain or develop a material safety
data sheet for each hazardous chemical they produce or import.
Distributors are responsible for ensuring that their customers
are provided a copy of these MSDSs. Employers must have an MSDS
for each hazardous chemical which they use. Employers may rely
on the information received from their suppliers. The specific
requirements for material safety data sheets are in paragraph
(g) of this section. There is no specified format for the MSDS
under the rule, although there are specific information requirements.
OSHA has developed a non-mandatory format, OSHA Form 174, which
may be used by chemical manufacturers and importers to comply
with the rule. The MSDS must be in English. You are entitled
to receive from your supplier a data sheet which includes all
of the information required under the rule. If you do not receive
one automatically, you should request one. If you receive one
that is obviously inadequate, with, for example, blank spaces
that are not completed, you should request an appropriately completed
one. If your request for a data sheet or for a corrected data
sheet does not produce the information needed, you should contact
your local OSHA Area Office for assistance in obtaining the MSDS.
The role of MSDSs under the
rule is to provide detailed information on each hazardous chemical,
including its potential hazardous effects, its physical and chemical
characteristics, and recommendations for appropriate protective
measures. This information should be useful to you as the employer
responsible for designing protective programs, as well as to
the workers. If you are not familiar with material safety data
sheets and with chemical terminology, you may need to learn to
use them yourself. A glossary of MSDS terms may be helpful in
this regard. Generally speaking, most employers using hazardous
chemicals will primarily be concerned with MSDS information regarding
hazardous effects and recommended protective measures. Focus
on the sections of the MSDS that are applicable to your situation.
MSDSs must be readily accessible
to employees when they are in their work areas during their workshifts.
This may be accomplished in many different ways. You must decide
what is appropriate for your particular workplace. Some employers
keep the MSDSs in a binder in a central location (e.g., in the
pick-up truck on a construction site). Others, particularly in
workplaces with large numbers of chemicals, computerize the information
and provide access through terminals. As long as employees can
get the information when they need it, any approach may be used.
The employees must have access to the MSDSs themselves - simply
having a system where the information can be read to them over
the phone is only permitted under the mobile worksite provision,
paragraph (g)(9) of this section, when employees must travel
between workplaces during the shift. In this situation, they
have access to the MSDSs prior to leaving the primary worksite,
and when they return, so the telephone system is simply an emergency
arrangement.
In order to ensure that you
have a current MSDS for each chemical in the plant as required,
and that employee access is provided, the compliance officers
will be looking for the following types of information in your
written program:
1. Designation of person(s)
responsible for obtaining and maintaining the MSDSs;
2. How such sheets are to
be maintained in the workplace (e.g., in notebooks in the work
area(s) or in a computer with terminal access), and how employees
can obtain access to them when they are in their work area during
the work shift;
3. Procedures to follow when
the MSDS is not received at the time of the first shipment;
4. For producers, procedures
to update the MSDS when new and significant health information
is found; and,
5. Description of alternatives
to actual data sheets in the workplace, if used.
For employers using hazardous
chemicals, the most important aspect of the written program in
terms of MSDSs is to ensure that someone is responsible for obtaining
and maintaining the MSDSs for every hazardous chemical in the
workplace. The list of hazardous chemicals required to be maintained
as part of the written program will serve as an inventory. As
new chemicals are purchased, the list should be updated. Many
companies have found it convenient to include on their purchase
orders the name and address of the person designated in their
company to receive MSDSs.
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