Safety Data Sheets

SDS Services

We provide professional Safety Data Sheet (SDS) authoring to meet the GHS and OSHA Hazcom 2012 requirements. HazCom is OSHA's most-cited manufacturing area. OSHA's most-cited areas for small chemical producers are Respiratory Protection and Hazard Communication. For larger producers it's the PSM standard, 29 CFR 1910.119, for which OSHA has a National Emphasis Program.

Safety Data Sheets are a key part of systems for compliance with OSHA's Hazard Communication requirements (29 CFR 1910.1200), EU Dangerous Preparations requirements (91/155/EEC, now superseded by REACH),  Canadian WHMIS and others.  Generally OSHA's requirements have been the least prescriptive (though that is changing), and there's usually a 3-year review/update requirement.  With OSHA's lack of mandated format, ANSI's Z400.1 Standard became generally accepted in North America and has since been updated to the GHS Safety Data Sheet format. 

Differences among these drove development of the  UN harmonization effort, the Globally Harmonized System of Classification and Labelling of Chemicals. The physical hazards section was led by the transportation sector, Health & Environmental by OECD and Hazard Communication by ILO.  Initially adopted in 2002, the current revision 7 was published August 2017; included are pictograms new to most users.  Most Asian countries and the EU have adopted this system; OSHA published a  Final Rule on March 26, 2012.

OSHA has actively worked with other groups, particularly SCHC, on harmonizing requirements and formats.  There is a good GHS comparison on the OSHA website.  Additionally, OSHA recognizes that many Safety Data Sheets are inadequate, and has developed an enforcement initiative. The training and format revision deadlines are passed.  Here is a link to Enforcement Guidance

Health Canada published WHMIS 2015 on February 11, 2015, with full implementation by December 1, 2018.

Current clients include oilfield services, pulp and paper, polymers, small chemical formulators, maritime and mining operations. We want your business, please contact us today.

Perceptions and misperceptions: I have encountered a number of people who request the H-Codes and P-Codes listed on their Safety Data Sheets. The Hazard HXXX codes and Precautionary PXXX codes are “intended to be used for reference purposes. It is not part of the … statement text” (Unlike the old EU codes). The codes are not included in GHS examples, and are absent in OSHA's HAZCOM 2012. Precedence rules allow some simplification, particularly related to the exclamation mark, which "should not appear" with the skull and crossbones, where the corrosive symbol is used for skin or eye irritation, or when the health symbol is used for sensitization or skin or eye irritation.

For additional information on Industrial Hygiene follow the link to Industrial Hygiene.

Involvement with Material Safety Data Sheets resulted from my industrial employer's reorganization. The best implementations of OSHA’s Hazard Communication standard (29 CFR 1910.1200) requirements for Safety Data Sheets followed the ANSI MSDS format (Z400.1).  GHS is the current best practice, first implemented in the EU and now by OSHA.