Safety Data Sheets
We provide professional Safety Data Sheet (SDS) authoring services 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OSHA's Hazard Communication requirements (29 CFR 1910.1200), EU Dangerous Preparations requirements (91/155/EEC, now superseded by REACH), Canadian WHMIS and others.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 changed), and there's usually a 3-year review/update requirement. When OSHA lacked a mandated format, ANSI's Z400.1 Standard became generally accepted in North America. The current standard is 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, included are pictograms new to most users. The current revision 9 was published in July 2021. OSHA published a Final Rule on March 26, 2012 and is now law, and has a Proposed Rule to update to a more recent revision.
OSHA has actively collaborated with other groups 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 mostly Texas and Louisiana oilfield services, pulp and paper, polymers, small chemical formulators, maritime and mining operations. Clients are throughout USA and some international. We want your business, please contact us today.
Perceptions and misconceptions: 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 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 Z400.1 MSDS format; GHS is the current best practice, first implemented in the EU and now by OSHA.