Understanding Safety Data Sheets: Your Complete Resource for Inspection Day Preparation
The United States Occupational and Health Administration (OSHA) regulates the protection of workers’ safety in the workplace. As an employer it is your duty under the law to understand how safety data sheets are used to help create a safe and healthy work environment for your employees.
What is a Safety Data Sheet?
Safety data sheets (sometimes referred to as simply SDS or SDS sheets) are generally physical papers providing safety information relating to hazardous chemicals in the workplace. Chemical safety data sheets are necessary to protect workers and required in many workplaces.
OSHA Hazard Communication Standard (HCS) 1910.1200(g) outlines the specific details regarding how chemicals are classified and how to ensure employees are aware of potential hazards as well as appropriate protective measures. Safety data sheets are one way employers are required to communicate this information.
Safety data sheets are typically organized and stored in dedicated SDS binders where employees have free access to the information throughout the day. Even if you are not familiar with safety data sheets themselves, you have likely seen highly visible yellow SDS binders in various industrial settings.
Do I Need to Worry About Safety Data Sheets?
If your business manufactures, imports and/or distributes hazardous chemicals, you are responsible for creating, maintaining and distributing the safety data sheets that accompany the chemicals. If your company uses hazardous chemicals in workplace operations, you are responsible for ensuring that each hazardous chemical has a safety data sheet that is made accessible to employees.
It should be noted, OSHA doesn’t require businesses to keep safety data sheets for household consumer products when/if they’re used in the same way a regular consumer would use them. For example, cleaning solutions kept on hand for occasional break room or bathroom cleaning.
On the other hand, safety data sheets are required for household consumer products that contain hazardous chemicals if employees are required to work with them more often (or for longer periods of time) than a regular consumer. For example, cleaning solutions provided for janitorial workers.
H3) Can Safety Data Sheets Be Electronic?
Safety data sheets can be electronic or physical, however it’s important to note that only providing electronic SDS information is not OSHA-compliant. Under OSHA regulation 1900.1200(g)(8), electronic SDS information must be readily accessible by workers, there must be a back-up system in case of emergencies (such as an external hard disk drive, optical disc drive or paper copies) and paper copies must still be provided to employees upon request.
Safety Data Sheets & GHS Chemical Labels
You may often hear reference to safety data sheets in association with GHS chemical labels. This is because OSHA HCS is aligned with the Globally Harmonized System of Classification and Labeling of Chemicals. This system, introduced by the United Nations, is generally referred to as simply GHS, or GHS guidelines.
GHS guidelines are exactly what their name implies: a standardized set of guidelines for the safe production, transport, handling and use of hazardous chemicals. As countries adopt the GHS in their hazard communication systems, it will help ensure that chemical hazards and protective measures are clearly communicated and easily understood worldwide.
OSHA requires both chemical labels and chemical safety data sheets to reflect HCS/GHS standards. Safety data sheets should contain all the information required to create OSHA-compliant GHS chemical labels along with more detailed chemical safety information.
SDS vs. MSDS: What’s the Difference?
Previous to GHS alignment, OSHA HCS required Material Safety Data Sheets (MSDS) for hazardous chemicals in the workplace. Post GHS alignment, OSHA HCS requirements have transitioned to Safety Data Sheets (SDS).
The main difference between MSDS and SDS sheets is how information is presented. Both documents communicate information regarding hazards and safety precautions for working with hazardous chemicals, however, safety data sheets are required by OSHA HCS 1900.1200(g).
While both types of chemical safety sheets generally contain similar information, safety data sheets present the information in a consistent format divided into sixteen sections. Each section, the order in which they should be listed and the information required align with GHS guidelines.
Converting MSDS to SDS
If your business manufactures or formulates chemicals, converting MSDS to SDS format is your responsibility. Safety data sheet authoring companies can provide this service, or it can be done internally with in-house experts (e.g. chemists).
If your business otherwise works with hazardous chemicals in a manner or quantity regulated by OSHA (see flowchart above), it is your responsibility to contact your chemical supplier and request SDS copies. As of June 2016 most material safety data sheets should have been converted to SDS format.
OSHA Requirements for Safety Data Sheets
OSHA requirements for safety data sheets include information about the physical, health and environmental hazards of each chemical as well as how to safely store, handle and transport them. As mentioned above, OSHA requires this information to be divided into sixteen specific sections in accordance with GHS guidelines.
Dividing safety data sheets into the GHS-specified sections not only ensures format consistency, but also organizes information in the most useful way for end users. For example, details needed quickly (such as what to do if a chemical is accidentally ingested) are listed first so they are most readily accessible in the case of an emergency.
Detailed Breakdown of the 16 SDS Sections
SDS Sections 1-8: General Information
The first eight sections of an SDS contain information most needed for quick access. Identifying the chemical, its composition, how it should be handled and stored, exposure limits, and what to do in a variety of emergency situations are all examples of information that would be found in Sections 1-8.
Section 1: Identification. Section 1 of an SDS is designed to tell you what the chemical is, how it should and should not be used, and how to contact the supplier. Required information includes product identifier, common names/synonyms, recommended use, restrictions on use and the name, address, phone number and emergency phone number of the manufacturer or distributor.
Section 2: Hazard(s) Identification. Section 2 warns you of risks associated with the chemical on that particular SDS. Required information includes hazard classification, signal word, hazard statements, pictograms, precautionary statements and descriptions of unclassified hazard. In the case of mixtures, the percentage that consists of an ingredient with unknown acute toxicity should also be disclosed.
Section 3: Composition/Information on Ingredients. The third section on an SDS tells you exactly what the product is made of, including impurities and stabilizing additives. Because chemical products can be a substance, a mixture and/or a mixture that is considered a trade secret, SDS Section 3 is a little trickier than Sections 1 and 2.
Required information for substances includes the chemical name, common name/synonyms, Chemical Abstracts Service (CAS) number and other unique attributes. Impurities and stabilizing additives shouldn’t be left out. Both have their own classifications and contribute to the overall classification of the chemical substance.
Safety data sheets for chemical mixtures must include the same information as substances with the following additions: chemical name and exact percentage (or concentration) of all ingredients classified as health hazards that are also present in an amount greater than the concentration limits or exhibit a health risk below the concentration limits.
Percentage ranges can be used on safety data sheets for mixtures with batch-to-batch variation, a group of substantially similar mixtures, or if there is a trade secret claim. If exact percentages are withheld due to a trade secret claim, a statement to that effect is required in Section 3.
Section 4: First Aid Measures. Section 4 is one of the most important sections of an SDS in case of emergency. Information required includes a description of symptoms and effects (both acute and delayed, first-aid instructions for exposure via inhalation, skin and eye contact, or ingestion, and recommendations for immediate medical care or special treatment when needed.
Section 5: Firefighting Measures. This part of an SDS tells you what to do in case of fire caused by the chemical. Required information includes, appropriate/not appropriate extinguishing equipment, special equipment/precautions for firefighters and advice on specific hazards that develop from the chemical during the fire.
Section 6: Accidental Release Measures. SDS Section 6 tells you what to do should the chemical be spilled, leaked or otherwise released. Required information includes emergency procedures, protective equipment and appropriate cleanup and containment methods.
Section 7: Handling and Storage. Section 7 provides a guideline for safely handling and storing chemicals. Requirements include information for safely handling the chemical to minimize release into the environment, general hygiene, as well as conditions for safe storage, specific storage needs and storage incompatibilities.
Section 8: Exposure Controls/Personal Protection. SDS Section 8 is designed to help you avoid personal exposure to chemicals in quantities or time periods longer than can be done so safely. It lists the maximum amount of personal exposure considered safe, and what personal protection should be used to handle the chemical safely.
Required information for exposure includes OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) and any other limits recommended for safety. Information required for protection includes appropriate engineering controls, personal protective equipment (PPE) and any special material and/or resistance requirements for PPE.
Sections 9-11: Technical & Scientific Information
Safety data sheets organize technical and scientific information into Sections 9 through 11 (and sometimes Section 16). The information required in these particular sections of the safety data sheet is very specific and detailed. If there is no relevant information for a required element in any of these sections, it must be stated on the SDS in the appropriate field.
Section 9: Physical and Chemical Properties. This section is where the chemical’s characteristics are listed on the SDS. The minimum required fields include: Appearance (physical state, color, etc.); Upper/lower flammability or explosive limits; Odor; Vapor pressure, Odor threshold; Vapor density; pH; Relative density; Melting point/freezing point; Solubility(ies); Initial boiling point and boiling range; Flash point; Evaporation rate; Flammability (solid, gas); Partition coefficient: n-octanol/water; Auto-ignition temperature; Decomposition temperature; and Viscosity.
Section 10: Stability and Reactivity. Section 10 tells you how stable the chemical is and the likelihood of hazardous reactions. Required information is divided into three clear sections:
- Reactivity: includes specific test data for the chemical, class or family.
- Chemical Stability: includes whether the chemical is stable or unstable (at regular room temperature) while in storage and being handled, any stabilizers that may be needed and any changes in physical appearance that indicate safety issues.
- Other: includes possibility of hazardous reactions, conditions to be avoided, incompatible materials and any known or anticipated hazardous decomposition products that could be produced because of use, storage or heating.
Section 11: Toxicological Information. This section of an SDS provides you with health risks associated with poisoning from the chemical. Information required includes routes of exposure, related symptoms, acute and chronic health effects, numerical measures of toxicity and whether or not the chemical is considered carcinogenic.
Sections 12-15: Information Governed by Other Agencies
It’s important to note, OSHA requires safety data sheets contain Sections 12-15 to uphold GHS guidelines, but does not enforce the content included in those sections. While not mandated by OSHA, content in SDS Sections 12-15 are enforced and governed by other agencies such as the Environmental Protection Agency (EPA).
Section 12: Ecological Information (non-mandatory). Section 12 includes information helpful for evaluating the environmental impact if the chemical (or chemicals) were released into the environment. Examples of this type of information include bioaccumulation potential, ozone layer depletion and groundwater absorption studies.
Section 13: Disposal Considerations (non-mandatory). This section tells you how to safely dispose of, recycle or reclaim the chemical and/or its container. Examples include appropriate disposal containers, disposal methods, physical and chemical properties that may affect disposal, language discouraging sewage disposal and any special precautions for landfills or incineration.
Section 14: Transport Information (non-mandatory). SDS Section 14 provides information for shipping and transporting hazardous chemicals by road, air, rail or sea. This type of information can include UN number and shipping name, transport hazard classes, packing group number, environmental hazard, bulk transport guidance and special precautions associated with transport.
Section 15: Regulatory Information (non-mandatory). Section 15 includes any additional safety, health, and environmental regulations not indicated anywhere else on the SDS sheet. Regional regulatory information is a common example of this type of information.
Section 16: Other Information
Section 16 is for communicating when the most recent update was made, and any other useful information not included anywhere else in the SDS. Information to record here includes when the SDS was prepared, the last known revision date, and where changes were made in the most recent revision.
Step-by-Step Guide to Starting Your SDS System
If you don’t have an SDS system in place, you may not be aware of the hazardous chemicals used in your facility. Ensure you aren’t missing any safety data sheets when it comes time for inspection and get on track for compliance with these steps.
Step 1: Compile Supplier List. Make a list of any suppliers that provide hazardous chemicals or other items that may emit hazardous chemicals during regular use, such as industrial cleansers and bulk processing materials.
Step 2: Request Chemical List from Suppliers. Ask each supplier for a list of any chemicals they’ve sent you in the last three years.
Step 3: Inventory Chemicals in the Workplace. Conduct a thorough review of the workplace to inventory all existing chemicals. Ensure all necessary information is gathered by providing supervisors with a form to record each chemical along with its storage location, amount and use.
Step 4: Request Current Safety Data Sheets from suppliers. Contact all suppliers from Step 1. Request current safety data sheets for all products they supply for you and maintain a checklist to keep track of what you receive.
Step 5: Index All Safety Data Sheets. Sort your safety data sheets alphabetically and assemble in SDS binders. If necessary, categorize safety data sheets by department/area.* Provide SDS binders tailored to each department/area and a master SDS binder for all departments/areas.
* In the case of employees exposed to hazardous chemicals while providing services in multiple locations (such as carpet cleaning, or pest control) it is necessary to also provide SDS binders for each vehicle so that each employee has access throughout the day.
Step 6: Review & Compare Information. Compare your master SDS binder with information gathered in Steps 2 & 3.
Step 7: Resolve Discrepancies. Any differences found in Step 6 should be fixed, and updated safety data sheets should be provided whenever necessary.
Step 8: Distribute Updated SDS Binders. Each department/area should have its own SDS binder. Keep local backup copies specific to each department/area and a master SDS binder in one central location.
How to Organize Your SDS Sheets
The best way to keep your safety data sheets in order and readily accessible is to assemble them alphabetically in a dedicated SDS binder. Ensuring chemical hazard information is quick and easy for employees to find is at the core of SDS compliance. The binder you choose and how you organize it should meet that requirement first and foremost.
A well-organized, complete SDS binder is divided into three sections: the company hazard communication policy, safety data sheets and relevant OSHA publications. For ease of use, it’s always a good idea to use A-Z dividers to keep your safety data sheets alphabetical.
Avery® Industrial Organization Tools & SDS Binder Checklist
SDS Binder: Binders for organizing safety data sheets should be durable and easily recognizable as containing safety data sheets. Highly visible, with large easy-to-read red letters, Avery yellow SDS binders are designed to withstand heavy-duty use in warehouses and other industrial facilities.
Safety Data Sheets: No chemical left behind. An SDS is required for every hazardous chemical used in the workplace if it’s used in a manner or quantity regulated by OSHA. Ensure safety data sheets are updated by periodically reviewing chemical inventory and reconciling with the contents of your master SDS binder.
Sheet Protectors: Non-glare super heavyweight sheet protectors shield your safety data sheets from damage in the most demanding environments. Using sheet protectors with a non-glare finish helps makes safety data sheets easier to read in case of an emergency.
Index Dividers: Preprinted plastic A-Z dividers are the most convenient way to keep your safety data sheets alphabetized. Preprinted tabs and multicolor dividers make it easy for people to locate the right SDS. Plastic dividers hold up better in industrial environments than paper or card stock.
Company Hazard Communication Policy: This document should include the person responsible for maintaining the SDS binder and what is expected of them.
Relevant OSHA Documentation: Relevant information published by OSHA that is useful or beneficial for workers should be printed and included in your SDS binder. Specific OSHA requirements for safety data sheets published as an OSHA brief and new OSHA instruction directives such as CPL-02-02-079 are great examples of documentation beneficial for encouraging chemical safety and compliance.
How Often Should You Update Your Safety Data Sheets?
When new chemicals are brought into the facility, updated safety data sheets should be added immediately. Diligently following this rule helps ingrain chemical safety compliance in company culture. Soon it will become routine for employees to continually update SDS binders and databases.
When new significant information about the hazards of a chemical (or new protection methods) becomes available, it must be added to the SDS within three months. This requirement is an OSHA-mandated SDS regulation to ensure the most accurate up-to-date information.
It is also a good idea to conduct a thorough chemical review every one to three years to assess which chemicals are active and which are no longer in use. This practice makes it easier to identify and resolve missing or misplaced safety data sheets. Older chemicals that are no longer used can be removed from active SDS binders and archived for reference to keep your binders streamlined.
Safety Data Sheet 16 Sections: Cheat Sheet
An easy way to make sure you’re always in line with SDS compliance is to keep a guideline available for convenient access. Save this handy list of SDS sections for easy access any time you need to review for compliance.
Encourage employees preparing safety data sheets and organizing your SDS binder to print and save this list or keep it posted on desktops.