The Next Revolutionary War?
For many, this transition period to OSHA HazCom 2012 from the Hazard Communication Standard of 1994 can best be summarized by Thomas Paine’s famous quote, “These are the times that try men’s souls.” While it was used in the pamphlet The American Crisis to deliver the ideas of the Revolution to the people of early America, there are many in the throes of classifying chemicals, substances and mixtures that feel this quote applies to daily life.
There is pressure on SDS authors, either internally or externally, to “get it right”. How can we be sure our classification is accurate? Did we cover all the hazards? Did we use the correct data? Should we check other sources? These last two questions can be the most difficult to answer.
To be a “good” SDS writer, never stop at just one source of data. Since OSHA chose not to use the exact language out of GHS Revision 3 and only selected certain building blocks when developing HazCom2012, care should be taken when utilizing classifications from other world areas. One has to remember that many other world areas did the same thing. Using classifications derived under another country’s system could lead to some over-classification, or under, depending on which country’s system is used.
A prime example of this would be Toluene. A straightforward colorless, insoluble, liquid chemical used mostly as a solvent, Continue Reading…
Which way do I go, George?
John Steinbeck’s novella “Of Mice and Men” is often a required reading for many school children. Though published in 1937 about a story of migrant workers in the Great Depression, it has many themes that are still powerful today. What many don’t know is that one of Steinbeck’s characters from this story is parodied in a classic Looney Tunes cartoon.
Of Fox and Hounds
In this cartoon, Willoughby the dog is fooled by George the fox. Willoughby is voiced by Tex Avery, while George’s voice is done by Mel Blanc.
Now what does this have to do with Safety Data Sheets or SDS? Often when tasked with writing a SDS one can feel like poor Willoughby. All of the information is available, but which way do you go. Which way do you go?
ICC Compliance Center can help and it won’t be in the way of George in the cartoon. We offer five different SDS Services.
But how do I choose which is right for me?
- SDS Creation: The process is simple. Send us a basic product information sheet, the raw materials SDS documents, and the countries involved and we can write an SDS for you that meets the requirements of OSHA HazCom 2012, WHMIS, European REACH, or European CLP. We even offer to sign a non-disclosure agreement to keep your product information private.
- SDS Reformats and Revisions: Most companies already Continue Reading…
Remember eating alphabet soup as a child? Remember playing with the noodle letters to make more words than your friends or siblings? Remember when the letters would not cooperate and random letters were floating in your bowl? Remember trying to use abbreviations and acronyms to make those random letters work? Oh, the frustration! Working on Safety Data Sheet (SDS) documents in the European Union (EU) can often feel like some of those memories.
ICC Compliance Center is here to help and possibly give some new ways to win in your next competition.
EU – Directives and Regulations
As a reminder, the EU governs hazard communication in two ways – by directives and regulations. Directives mean all member states are required to implement their version of the directive within their state. Regulations, however, mean complete implementation in all member states without the need for or allowance of versions in each state.
Current directives and regulations
As of February 2015, there are multiple active directives and regulations at work in the EU. The oldest is the Dangerous Substances Directive (67/548/EEC) or the DSD and the Dangerous Preparations Directive (1999/45/EC) which is the DPD. This is followed by the Registration, Evaluation, Authorization and Restriction of Chemical Substances Regulation more commonly known as REACH (EC1907/2006). Finally, there is the Regulation on Classifying, Labeling and Packaging of Substances and Mixtures (1272/2008/EU) or in the shortened form the CLP. It should be mentioned Continue Reading…
After a few recent inquiries regarding reliability of information on MSDS (material safety data sheets), I began to reflect on the various ways that MSDS are used and abused. Having been around during the introduction of standardized MSDS in Canada and still being here (!) for their next incarnation as “SDS” (safety data sheets – the GHS version expected under “WHMIS 2.0” and currently defined in US “Hazcom 2012”). It seemed like an appropriate time to consider if we’re likely to avoid some of the confusion that’s been around since the late 80’s.
One of the key points to remember about MSDS-SDS is that, although they may be used for other purposes their primary function in North America has been to provide health and safety information to workers in occupational settings. This is continuing, so far, in the GHS age – the authorities prescribing the content and use of SDS are those responsible for Occupational Health and Safety (i.e. US-OSHA, Health Canada, provincial Ministries of Labour, etc.). Information on other regulatory aspects- environmental, transportation classification, etc. – while provided for, is not mandatory unless these other agencies incorporate MSDS-SDS requirements into their regulations.
Consequently it is risky to unconditionally rely upon the information presented in DG/Hazmat or regulatory (e.g. TSCA/NPRI/DSL, etc.) sections which may be country-specific or out-of-date since the OHS regulations do not consider this information mandatory.
Here at ICC Compliance Center and depending on your application, we may ask you for a CAS number. When we create labels on demand for your exports, among other services, we will ask you to provide us with the chemical name and CAS number and then we are able to provide as few as 100 GHS compliant labels and/or a compliant SDS.
Compliant GHS Chemical Label:
A CAS number or CAS Registry number is a unique identifier for every chemical substance dating back to 1957. The Chemical Abstracts Service (CAS) is the responsible entity that is responsible for assigning a unique number to every chemical described in scientific literature.
A CAS number itself has no meaning. Its primary use is to avoid confusion between chemicals with similar names, or individual chemicals that may have multiple names. It is also used to identify the chemical when a generic or trade name is used.
A CAS Registry Number is separated by hyphens into three parts, the first consisting of up to seven digits, the second consisting of two digits and the third consisting of a single digit.
In short, the CAS number can be particularly useful in database searches because it allows you to search a database and easily pull every record for that particular substance or chemical. For example, “Methanol” is known by multiple names such as methyl alcohol, methyl hydrate, hydroxymethane and Continue Reading…
Take a company that manufactures artist’s paints. They could sell hundreds of colors and most are made with the same “base” ingredients. Start adding the colorant, dye or pigment, and all of a sudden you have the potential for hundreds of unique ingredients and the potential for some differences.
What many folks do not understand is that each colorant, dye or pigment may have different hazards. The classification could change from paint to paint. It is imperative that each colorant, dye or pigment is researched to see if it meets any of the hazard criteria. Products may look the same once they are sitting on a shelf, but can be dramatically different in chemical composition. If something different occurs in the profile of hazards, then (M)SDS needs modified to be accordingly. We also strongly recommend a separate (M)SDS when the hazards are found to be different from the colors.
Add wanting to prepare an MSDS for Canada, the USA or Europe, and you have a variety of different disclosure criteria, cut-off values etc. Something that is regulated in one country may not be in another.
ICC takes pride in ensuring that SDSs we author meet the requirements of the WHMIS, OSHA or European regulations. Contact us for details on how we can help.
Discussion thread at LinkedIn
One of the major changes that workplaces will see under OSHA’s new Hazcom 2012 regulations has to do with Material Safety Data Sheets. OSHA has decided to align their requirements with the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Safety Data Sheet (SDS) preparation requirements. What industry has historically called a Material Safety Data Sheet, or MSDS, will now be referred to as simply a Safety Data Sheet, or SDS.
Along with the new name, the SDS’s will have specific requirements for content. SDS’s under the Hazcom 2012 regulations are required to follow a 16 section format and include specific information in each section. The required sections are as follows:
- Section 1, Identification
- Includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
- Section 2, Hazard(s) identification
- Includes all hazards regarding the chemical; required label elements.
- Section 3, Composition/information on ingredients
- Includes information on chemical ingredients; trade secret claims.
- Section 4, First-aid measures
- Includes important symptoms/effects, acute, delayed; required treatment.
- Section 5, Fire-fighting measures
- Lists suitable extinguishing techniques, equipment; chemical hazards from fire.
- Section 6, Accidental release measures
- Lists emergency procedures; protective equipment; proper methods of containment and cleanup.
- Section 7, Handling and storage
- Lists precautions for safe handling and storage, including incompatibilities.
- Section 8, Exposure controls/personal protection
- Lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
- Section 9, Physical and chemical properties
I always cringe when someone asks me what I do for work. Not because I dislike my job (in fact, I’m one of the few people I know who truly enjoys their work) but because it’s so complicated to explain what I do! Sure, I could simply say I’m a Regulatory Specialist and let them stare at me blankly and try to figure out what that means, but they usually expect more of an explanation.
After going through the explanation for a new acquaintance yesterday, I got to thinking that many of our customers may not know exactly what ICC’s Regulatory Specialists do either. Some of my “regular” customers only deal with one aspect of my expertise, and are often surprised when they learn how many hats I really wear on a regular basis. After 8 years on the job, I have collected many responsibilities to keep me on my toes.
- Training – One of the main duties of the Regulatory Specialist (RS) at ICC is to deliver training classes to our customers. For me, this includes the US 49CFR Hazmat regulations, the IATA Dangerous Goods Regulations and the IMDG Code. These classes can take place at our training centers, the customer’s facility, a hotel, or even via an online webinar. Not only do we conduct the training, but we also develop the presentations and quizzes that are Continue Reading…
I was recently asked to give an overview of how MSDS’s are used in the workplace to some of my coworkers. Coming from a laboratory background, I often forget that many people do not know what an MSDS (or Material Safety Data Sheet) is and why they are important in the workplace. For those of you who may not be familiar with what an MSDS is or how and why it is a very important piece of safety equipment in the workplace, here are few highlights.
What is an MSDS?
An MSDS is a document that provides safety information for a product or material. MSDS’s are generally used in a workplace or emergency situation and contains information such as:
- Hazards of the product
- Safe use of the product
- Symptoms of exposure to the product
- First aid procedures
- Emergency procedures
Who uses an MSDS?
- Employees who need to know proper safety and handling information for a product or material they use occupationally in the workplace
- Employers or employees who need to provide safety training and equipment
- Employers or employees who need to determine proper storage for materials
- Emergency response personnel; such as firefighters, first responders, EMT’s and ER personnel
- MSDS’s are not intended to be used by consumers for household use of products!
How are MSDS’s formatted?
Currently, there is not one MSDS format that is recognized worldwide.
- The US follows the OSHA requirements (no specific format is required, but the ANSI standard format may Continue Reading…