1. Prepared by
Consultation Education & Training (CET) Division
Michigan Occupational Safety & Health Administration
Michigan Department of Licensing and Regulatory Affairs
www.michigan.gov/miosha
(517) 322-1809
(Revised: 08/23/13)
2. Agenda
Overview of changes to the MIOSHA Part 42, 92 and
430: Hazard Communication Standard (Haz Com)
Labeling requirements
Safety Data Sheets (SDS) format – 16 sections
Supplemental Employee Training (to be provided
by employer)
3. Why the Change to Haz Com?
To align with the Globally Harmonized
System of Classification and Labeling of
Chemicals (GHS) adopted by 67 nations
To provide a common and coherent
approach to classifying chemicals
• Reduce confusion and increase
understanding of the hazards
• Facilitate training
• Help address literacy problems
4. Who is Affected?
Manufacturers, Distributors, Importers
Change SDS information and format
Change container labeling
Employers
Training employees on changes to:
SDS (change from MSDS to SDS and 16-section format)
Container Labels (including secondary containers)
Employees
Recognize and understand hazards based on:
Information in new SDS format
Pictograms on container labels
Precautionary and hazard statements
5. Other Standards Affected – Health
(signage requirements)
Asbestos
Carcinogens
Vinyl Chloride
Inorganic Arsenic
Lead
Cadmium
Benzene
Coke Oven Emissions
Acrylonitrile
Ethylene Oxide
Formaldehyde
Methylenedianiline
DANGER
WARNING
LEAD WORK AREA
POISON
NO SMOKING OR EATING
New Sign
“LEAD”
LEAD
MAY DAMAGE FERTILITY
OR THE UNBORN CHILD
CAUSES DAMAGE TO THE
CENTRAL NERVOUS
SYSTEM
DO NOT EAT, DRINK OR
SMOKE IN THIS AREA
6. Other Standards Affected
Flammable and Combustible Liquids
Spray Finishing using Flammable and
Combustible Materials
Process Safety Management of Highly Hazardous
Chemicals (PSM)
Hazardous Waste Operations and Emergency
Response (HAZWOPER)
Hazardous Work In Laboratories
Dipping and Coating Operations
Welding, Cutting and Brazing
Employee Medical Records and Trade Secrets
7. Effective Dates and Requirements
Effective Completion
Date
Requirement(s)
Responsible Party
December 1, 2013
Train employees on the new label
elements and SDS format
Employers
June 1, 2015
Compliance with all modified provisions
of the final rule except:
Chemical
manufacturers,
importers, distributors,
and employers
December 1, 2015
The distributor shall not ship containers
labeled by the chemical manufacturer or
importer unless it is a GHS label
Distributor
June 1, 2016
Update alternative workplace labeling
and hazard communication program as
necessary, and provide additional
employee training for newly identified
hazards [and affected vertical standard
specific signage]
Employer
Transition Period: 12/2012
to the effective completion
dates noted above
May comply with either MIOSHA Part 42,
92 and 430 (final standard), or the
current standard, or both
Chemical
manufacturers,
importers, distributors,
and employers
8. Chemical Classifications
Chemicals will be classified using a
harmonized system that provides standardized
language for:
Health Hazard Categories
Physical Hazard Categories
Environmental Hazard Categories*
*Not regulated by MIOSHA.
9. Chemical Classifications:
Health Hazards
Acute Toxicity
Skin Corrosion/Irritation
Respiratory or Skin Sensitization
Germ Cell Mutagenicity
Carcinogenicity
Reproductive Toxicity
Specific Target Organ Toxicity – Single Exposure
Specific Target Organ Toxicity – Repeated Exposure
Aspiration
Simple Asphyxiants
10. Chemical Classifications:
Health Hazards
Hazard Class
Acute toxicity
Skin Corrosion/Irritation
Serious Eye Damage/Eye Irritation
Respiratory or Skin Sensitization
Germ Cell Mutagenicity
Carcinogenicity
Reproductive Toxicity
Specific Target Organ Toxicity – Single Exposure
Specific Target Organ Toxicity – Repeated Exposure
Aspiration
Simple Asphyxiants
Hazard Category
1
1A
1
1
1A
1A
1A
2
1B
2A
3
1C
2B
1B
1B
1B
2
2
2
1
2
3
1
2
1
Single Category
4
2
Lactation
14. Chemical Classifications:
Physical Hazards
Hazard Class
Explosives
Flammable Gases
Flammable Aerosols
Oxidizing Gases
Gases under Pressure
Compressed gases
Liquefied gases
Refrigerated liquefied gases
Dissolved gases
Flammable Liquids
Flammable Solids
Self-Reactive Chemicals
Pyrophoric Liquids
Pyrophoric Solids
Pyrophoric Gases
Self-Heating Chemicals
Chemicals in which contact with
water emit flammable gases
Oxidizing Liquids
Oxidizing Solids
Organic Peroxides
Corrosive to Metals
Combustible Dust
Unstable
Explosives
1
1
1
Hazard Category
Div 1.1
Div 1.2
Div 1.3
Div 1.4
Div 1.5
Div 1.6
3
4
Type C
Type D
Type E
Type F
Type G
Type D
Type E
Type F
Type G
2
2
1
1
1
Type A
1
1
Single Category
1
2
2
Type B
1
2
3
1
1
Type A
1
2
2
Type B
3
3
Type C
Single Category
2
15. Labels
There are several new
label elements:
Symbols called
“Pictograms”
Signal Words
Hazard Statements
Precautionary
Statements
Product Identification
Supplier/Manufacturer
Identification
www.osha.gov/Publications/HazComm_QuickCard_Labels.htm
16. Labels: Shipping
Shipping Container Label
(55 gallon/200 liter drum)
Effective June 1, 2015 all
shipping labels will be
required to have all GHS
label elements
Pictograms within
DOT label
DOT Shipping
Flammable liquids,
toxic, n.o.s.
(contains XYZ)
UN 1992
18. DOT and MIOSHA Labels
DOT labels may take precedence over similar GHS
pictograms for shipping containers.
DOT does not have labels that correspond to the
“Health Hazard” or the “Acute Toxicity” (less
severe = exclamation mark).
19. Labels: Pictograms
There are 9 pictograms. Only 8 are regulated by
MIOSHA
Health Hazards
Physical Hazards
Environmental Hazards (Regulated by DEQ)
DEQ
23. Labels: Pictograms – Physical
Hazards
(continued)
Corrosive to Metals
Oxidizer
Gases under Pressure
24. Labels: Signal Word
These are words used to indicate the severity of the
hazard and alert employees to the potential hazard.
Only 2 signal words will appear:
“DANGER”(more severe hazard)
“WARNING” (less severe hazard)
Not all labels will have a signal word. Some chemicals
are not hazardous enough to require that a signal word
appear on the label.
25. Labels: Hazard Statement
There are specific hazard statements that must appear
on the label based on the chemical hazard
classification.
Examples:
Flammable liquid and vapor
Causes skin irritation
May cause cancer
26. Labels and other forms of warning –
Precautionary Statements
Recommended measures related to:
Prevention
Response
Storage
Disposal
Examples:
Wear respiratory protection
Wash with soap and water
Store in a well ventilated place
Not a mandate for employers/employees to follow.
28. Label: Other information
Other information that may be included on the label:
Physical state
Color
Hazards not otherwise classified
Route of exposure
Storage and disposal
Hazard prevention and emergency
response instructions
29. Pictograms
(Flammable and Acute Toxicity – Severe)
ToxiFlam (Contains: XYZ)
Product Identifier
Signal Word
Danger!
Toxic If Swallowed, Flammable Liquid and Vapor Hazard Statements
Do not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container
tightly closed. Keep away from heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face
protection. Ground container and receiving equipment. Use explosion-proof electrical equipment. Take
precautionary measures against static discharge.
Use only non-sparking tools. Store in cool/well-ventilated place.
IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician. Rinse mouth.
Precautionary
In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam.
Statements
Supplemental
Information
See Safety Data Sheet for further details regarding safe use of this product.
MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 966 6666 Supplier Identification
30. Secondary Container Labels
Excerpt from the Hazard Communication Standard (f):
(6) Workplace labeling. Except as provided in paragraphs (7) and (8)
of this section, the employer shall ensure that each container of
hazardous chemicals in the workplace is labeled, tagged or marked with
either:
(i) The information specified under paragraphs (1)(i) through (v) of
this section for labels on shipped containers [GHS Label]; or,
(ii) Product identifier and words, pictures, symbols, or combination
thereof, which provide at least general information regarding the
hazards of the chemicals, and which, in conjunction with the other
information immediately available to employees under the hazard
communication program, will provide employees with the specific
information regarding the physical and health hazards of the hazardous
chemical [e.g. HMIS, NFPA or other label system].
31. Labels: Secondary containers
Must be consistent with the revised Haz Com
standard
No conflicting hazard warnings or pictograms.
May use written materials (e.g., signs, placards,
etc.) in lieu of affixing labels to individual
stationary process containers.
Employer can use GHS compliant labels (same as
shipping).
HMIS Label
HEALTH
FIRE
PHYSICAL HZ
PPE
NFPA Label
Must include notation
of chronic health
effects
32. Safety Data Sheets
Under the new Haz Com
Standard, Material Safety Data
Sheets (MSDS) are now called
Safety Data Sheets (SDS).
All SDSs will have a consistent
16-section format.
Employers must ensure that
SDSs are readily accessible to
employees.
Safety
Material
Data
Safety
Sheets
Data
Sheets
33. Safety Data Sheets (SDSs)
New 16-section standardized SDS format required (ANSI Z400.1)
Section 1 – Identification
Section 2 – Hazard(s) identification
Section 10 – Stability and Reactivity
Section 11 – Toxicological Information
Section 3 – Composition / Information
on Ingredients
Section 12 – Ecological Information*
Section 4 – First-aid Measures
Section 5 – Fire-fighting Measures
Section 6 – Accidental Release
Measures
Section 7 – Handling and Storage
Section 8 – Exposure Controls /
Personal Protection
Section 9 – Physical and Chemical
Properties
Section 13 – Disposal Consideration*
Section 14 – Transport Information*
Section 15 – Regulatory Information*
Section 16 – Other information
including date of preparation of last
revision
*Sections outside of MIOSHA
jurisdiction but inclusion of
these sections is necessary
for a GHS compliant SDS
34. Safety Data Sheets (continued)
Section 1 – Identification:
Identifies the chemical on the SDS as well as the
recommended uses. It also provides the essential
contact information of the supplier.
Section 2 - Hazards Identification:
Hazards of the chemical presented on the SDS
Appropriate warning information associated with
those hazards.
35. Safety Data Sheets (continued)
Section 3 – Composition / Ingredients:
Identifies the ingredient(s) contained in the product
indicated on the SDS, including:
impurities and stabilizing additives.
information on substances, mixtures, and all
chemicals where a trade secret is claimed.
Section 4 - First-Aid Measures:
Describes the initial care that should
be given by untrained responders to an
individual who has been exposed to the chemical.
36. Safety Data Sheets (continued)
Section 5 – Fire-Fighting Measures:
Provides recommendations for
fighting a fire caused by the
chemical.
Section 6 - Accidental Release Measures:
Provides recommendations:
Appropriate response to spills, leaks, or releases, (e.g.
containment and cleanup practices)
Response for large vs. small spills, if different.
37. Safety Data Sheets (continued)
Section 7 – Handling and Storage:
Provides guidance on the safe handling
practices and conditions for safe storage of
chemicals.
Section 8 – Exposure Controls /
Personal Protection:
Indicates the exposure limits, engineering
controls, and personal protective measures
that can be used to minimize worker exposure.
38. Safety Data Sheets (continued)
Section 9 – Physical and Chemical Properties:
Identifies physical and chemical properties associated
with the substance or mixture.
Section 10 – Stability and Reactivity
Describes the reactivity hazards of the chemical and
the chemical stability information. Includes:
reactivity, chemical stability,
and other.
39. Safety Data Sheets (continued)
Section 11 - Toxicological Information:
Identifies toxicological and health effects information
or indicates is data unavailable.
Section 12 – Ecological Information*
Section 13 – Disposal Consideration*
Section 14 – Transport Information*
Section 15 – Regulatory Information*
*Sections are outside of MIOSHA jurisdiction but
must be included for a GHS compliant SDS.
40. Safety Data Sheets (continued)
Section 16 – Other Information
Indicates when the SDS was prepared or when the last
known revision was made.
The SDS may also state where the changes have been
made to the previous version.
43. Has the following been provided
by the employer?
Employers must provide employees with the details of
the facility specific hazard communication program:
Location and availability of written program and SDSs
Specific information related to chemicals in the facility:
Physical
Hazards;
Health Hazards;
Hazards not otherwise classified.
44. Has the following been provided
by the employer? (continued)
Chemical list, location and use of
hazardous chemicals
Secondary container labeling system
Specific procedures to follow to
protect employees from the chemical
hazard
Methods used to detect the presence
or release of hazardous chemicals
(sensor alarms, odors, visual other
monitoring devices)
?
45. Federal OSHA Resources
Haz Com Web Page - www.osha.gov/dsg/hazcom/index.html
Regulatory
Haz Com 2012 Final Rule
Haz Com Comparison:
Haz Com 1994 and 2012
Side-by-side
Redline Strikeout of the
Regulatory Text
FAQs
Guidance
OSHA Briefs
Fact Sheet
Quick Cards
Labeling
Safety Data Sheets
Pictograms
Effective Dates
OSHA Guide to GHS
www.osha.gov/dsg/hazcom/ghs.html
GHS documents (links to purple
book)
46. MIOSHA Resources
GHS Webpage on MIOSHA Website
www.michigan.gov/lara/0,4601,7-154-61256_11407284831--,00.html
Employee Training PowerPoint
CET library handouts:
CET-5531 - GHS Overview of Major Changes
CET-5532 – Lists other affected Standards
CET-5533 – Signage Changes
CET DVDs/Video Lending library services
State-wide Outreach seminars
Guidance documents & Revised posters
47. Training Summary
Today’s training program included:
Overview of changes to the MIOSHA Part 42, 92
and 430: Hazard Communication Standard (Haz
Com)
Labeling requirements
Safety Data Sheets (SDS) format – 16 categories
Details of the facility specific hazard
communication program
Resources
48. Questions
Contact MIOSHA for information or assistance:
MIOSHA Consultation Education and Training
7150 Harris Drive, P.O. Box 30643
Lansing, Michigan 48909-8143
(517) 322-1809
www.michigan.gov/miosha
Notas del editor
Last revised: 08/23/13 – Jenelle’s updates
This training session is designed to provide information to employees who work with hazardous chemicals and substances. Employers are required to provide training to employees by December 1, 2013.
08/16/13: Minor revisions were made associated with the compliance dates listed in the speakers notes on a few slides.
This training includes:
An overview of the changes to the MIOSHA Haz Com Standard;
The new labeling requirements;
Information on the new safety data sheets in the 16 section format; and,
Details of the facility specific haz com program. This portion of the training program is designed to provide guidance to employers on information they must include in order for the employee training program to be compliant with the MIOSHA Haz Com Standard.
So, why the change?
Since 1992, the United Nations have been working to create and enhance a globally harmonized system for the classification and labeling of chemicals that can be used by importers, distributers and manufacturers worldwide.
2012 Haz Com revised standard is based on GHS revision 3.
The goal is to provide a common and coherent approach to classifying chemicals.
This will benefit employees as it will:
Reduce confusion and increase understanding of the hazards.
Facilitate training
Help address literacy problems particularly due to use of pictograms
This slide lists the other MIOSHA standards that are affected by the changes adopted in the 2012 Haz Com.
Language on required signs in the listed standards, will be harmonized with Haz Com and GHS.
For example the sign for lead will be changed as noted above.
Chromium (VI) does not appear to have any changes.
Refer to the signage handout (CET-5533) or the GHS page on the MIOSHA website, for additional information on signage requirements.
http://www.michigan.gov/documents/lara/lara_miosha_cet5533_402987_7.docx
Note: Label requirements for substance specific standards must be completed on or by June 1, 2015.
Example: Asbestos pipe wrap (thermal system insulation) label must have be new language and placed by June 1, 2015, but the sign for the regulated area (area under abatement) must be updated by June 1, 2016.
Here is a list of the other standards affected.
In some cases, definitions may have changed in the standards listed above.
Chromium (VI) does not appear to have any changes.
Refer to the handout CET-5532 or the GHS page on the MIOSHA website, for additional information on the other Standards affected:
http://www.michigan.gov/documents/lara/lara_miosha_cet5532_402986_7.doc
This chart was provided by Federal OSHA with one addition which is noted in brackets.
Effective on or by June 1, 2015:- All SDS must be completed and shipped/sent to users with the 1st order shipped on or after June 1, 2015.
Employers/users of chemicals review to ensure all SDS received on or after June 1, 2015 are in the new format.
Per OSHA, employers are not required to pursue getting new SDSs for products received before June 1, 2015; unless they are aware of changes to the hazards in the product. For older products, material safety data sheets for the products must kept as long as chemical is onsite/use,d then archived as required.
- Vertical chemical specific standards with label requirements must be changed to harmonize with 1910.1200 Haz Com.
Effective on or by June 1, 2016
- Employer/user must have program updated including any additional training and any label changes completed.
- Vertical chemical specific standards with signage requirements will be changing to harmonize with 1910.1200 Haz Com. The added text in brackets reflects this.
Previously, chemical hazards were evaluated in a more subjective manner.
Chemicals must now go through a specific, prescriptive classification process to determine which hazards are present and which hazard and precautionary statements apply. This can be a lengthy process.
Environmental Hazards are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: [email_address]
Now there are 10 established chemical health classifications; that are further defined and described in Appendix A of the Haz Com Standard.
Appendix A is to be used by manufacturers, importers and distributers to determine if any of their products are classified as a health hazards. If the product is classified as a health hazard in one or more of the 10 health hazard classifications listed on this slide, Appendix A is used to determine the severity of the hazard (or hazard category) under the applicable hazard class. More information noted in the chart on the next slide.
Note: Simple Asphyxiants are not part of the current GHS (international standard) but were specifically included by OSHA as a hazard classification under the 2012 Haz Com Standard.
This chart shows the new health hazard classes and the hazard categories that correspond to each of the health hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart.
Manufacturers, importers and distributers must classify all hazards for their products.
Each of the chemical physical classifications are further defined and described in Appendix B of the Haz Com Standard.
Appendix B is to be used by manufacturers, importers and distributers to determine if any of their products are classified as a physical hazard. If the product is classified as a physical hazard in one or more of the physical hazard classifications, Appendix B is used to determine the severity of the hazard (or hazard category).
Note: Pyrophoric Gases and Combustible Dust are not part of the GHS (international standard) but were specifically included by OSHA as physical hazard classifications under the 2012 Haz Com Standard.
This chart shows the physical hazard classes and the hazard categories that correspond to each of the physical hazard classes. Hazard category 1 (or column furthest to the left) is the most hazardous. Hazard categories become less severe as you move to the right in the chart.
Manufacturers, importers and distributers must classify all hazards for their products.
This is an example of the new label style that is to appear on product labels beginning no later than June 1, 2015 (or Dec. 1, 2015 for distributers who still have product in inventory after the June 1, 2015 deadline).
The type of required information is noted in blue. The actual statements and information will vary depending on the specific health and physical classification of the product.
Note the difference in the shipping label compared to the container label on the previous slide. Department of Transportation (DOT) requires that additional information be noted on shipping containers. See bottom right corner of the label for shipping.
MIOSHA requires that employees are knowledgeable of both the container and shipping labels.
Source: GHS Guide on OSHA website: http://www.osha.gov/dsg/hazcom/ghs.html#3.1
Figure 4.10
These are DOT labels and may appear on transport containers depending on the classification of the chemical. Employers are required to train employees on shipping container labels they may encounter on the job.
DOT does not view the GHS pictograms as a conflict and it is permissible to have the DOT and GHS pictogram for representing the same hazard. OSHA will not be enforcing the “shall not appear” requirement in Appendix C (C.2.3.3. states “where a pictogram required by DOT under Title 49 of the CFR (code of federal regulations) appears on a shipped container, the pictogram specified in C.4 for the same hazard, shall not appear.”
There are 3 pictograms specific to health hazards: exclamation, health hazard (silhouette of a person with starburst on the chest) and skull and crossbones.
There is 1 pictogram that can represents both physical and/or health hazard of corrosive.
There are 4 pictograms specific to physical hazards: exploding bomb, flame, flame over circle (oxidizer) and gas cylinder.
There is 1 for environment: Environmental Hazards are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: [email_address]
The following slides will provide more detail related to the pictograms.
These 2 pictograms are specific to acute toxicity (short-term exposure). The skull and crossbones is for any substance that is classified as having acute toxicity in health hazard category 1-3. The acute toxicity health class, category 4 (least hazardous) is represented by an exclamation mark.
If the substance is properly labeled, these 2 pictograms will never appear on the same label. It will be one or the other with skull and crossbones representing the more severe hazard.
Additional information for labeling and language associated with these pictograms is found in Appendix C of the Haz Com Standard.
Most employees should be familiar with the pictogram for corrosion on the left.
The pictogram to the right is called the “health hazard” pictogram and is represented by the silhouette of a person with a starburst across the chest. This is used indicate that the substance is a chronic and/or target organ hazard.
The next 2 slides (4 pictograms) represent physical hazards.
Note that the corrosive pictogram used to designate corrosion to metal is the same pictogram used for skin corrosion/serious eye damage/eye irritation under the health hazard classification.
Not all health hazards represented by this pictogram are corrosive to metal so it is important to look for additional information on the label and in the SDS.
Oxidizers are chemicals that can emit oxygen and increase the risk of fire.
In the past, there have been several signal words that may have been used to indicate a hazard like caution, warning, danger.
The GHS permits the use of only 2 signal words: “Danger” and “Warning”. Only 1 of the signal words is permitted to appear on the label based on the classification of the chemical.
Definition of Hazard Statement:
"Hazard statement" means a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
Manufacturers, importers and distributers use the classification system outlined in GHS to identify which statements must appear in the SDS and on the label found in Appendix C.
"Precautionary statement" means a phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. Precautionary statements can be found in Appendix C.
Definition of product identifier:
"Product identifier" means the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS.
This is discretionary information that may be provided by the manufacturer, importer or distributer. This information is not required to be on the label; however it will be found in the SDS.
Slide is animated to identify each required section/element of the new label.
Product Identifier = name or number unique to the chemical listed on the manufacturer label or in SDS.
Note: waste container labeling requirements are covered under EPA/DEQ rules. Contact DEQ for additional information.
HMIS = Hazardous Materials Information System (American Coatings Association)
NFPA = National Fire Protection Association
HMIS labeling system incorporates an “*” to inform employees of the presence of a chronic/target organ health effect. NFPA labeling system does not incorporate chronic effects and this must be included on NFPA labeled secondary containers if noted on the original manufacturer container. The health hazard pictogram (silhouette of a person with starburst on chest).
GHS vs. HMIS / NFPA 704
NFPA & HMIS systems number “4” indicates a severe hazard.
Under GHS Haz Com standard, when a manufacturer, importer, distributer classifies a chemical, a category “4” is the least severe and category “1” in the most severe.
GHS hazard category numbers may be noted in SDS; NOT required to be present on the container label.
ACA made modifications to HMIS ratings in 2001. Reactivity was changed to Physical Hazard and defined ranges modified. System is still 0 = least hazard and 4=greatest hazard) More information available at www.paint.org/programs/hmis.html
Manufacturers, importers and distributers may begin using the new 16-section format SDS (follows the ANSI standard) during the transition from the 1994 Haz Com standard and the final 2012 Haz Com standard but no later than June 1, 2015. They are required to provide a revised copy of the MSDS/SDS to the employer anytime changes are made.
Employers are required to maintain copies of all SDSs for the chemicals used and/or stored within the work area. They should have a system to ensure all SDSs are present/accounted and to periodically check for the most current SDS (usually based on revision date) when received from a manufacturer, importer or distributer.
The employer is to maintain a copy of the most current SDS and archive prior MSDSs/SDSs. SDSs are to accessible/available to employees.
As stated previously, if manufacturer is no longer in business, material safety data sheet for the product must kept as long as chemical is onsite/used then archived as required.
Manufacturers, importers and distributers may begin using the new 16-section format SDS during the transition from the 1994 Haz Com standard and the final 2012 Haz Com standard but no later than June 1, 2015. They are required to provide a revised copy of the MSDS/SDS to the employer anytime changes are made.
Employers are required to maintain copies of all SDSs for the chemicals used and/or stored within the work area. They should have a system to ensure all SDSs are present/accounted and to periodically check for the most current SDS (usually based on revision date) when received from a manufacturer, importer or distributer.
The employer is to maintain a copy of the most current SDS and archive prior MSDSs/SDSs. SDSs are to be accessible/available to employees.
Appendix D provides additional requirements for the information to be included under each section heading.
Section 1 requires restriction(s) on use.
Section 2 requires: Classification Signal word, symbols, hazard and precautionary statements, Hazards not otherwise classified, Unknown toxicity statements when 1% or more of the components has unknown toxicity. “X percent of the mixture consists of ingredients of unknown toxicity.”
Section 3 requires percentage.
MIOSHA will not enforce sections 12 – 15.
Sections 12-15 are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: [email_address]
Section 1
The required information consists of:
• Product identifier used on the label and any other common names or synonyms by which the
substance is known.
• Name, address, phone number of the manufacturer, importer, or other responsible party, and
emergency phone number.
• Recommended use of the chemical (e.g., a brief description of what it actually does, such
as flame retardant) and any restrictions on use (including recommendations given by the
supplier).
Section 2
The required information consists of:
• The hazard classification of the chemical (e.g., flammable liquid, category1).
• Signal word.
• Hazard statement(s).
• Pictograms (the pictograms or hazard symbols may be presented as graphical reproductions
of the symbols in black and white or be a description of the name of the symbol (e.g., skull
and crossbones, flame).
• Precautionary statement(s).
• Description of any hazards not otherwise classified.
• For a mixture that contains an ingredient(s) with unknown toxicity, a statement describing how
much (percentage) of the mixture consists of ingredient(s) with unknown acute toxicity. Please
note that this is a total percentage of the mixture and not tied to the individual ingredient(s).
Section 3
The required information consists of:
Substances
• Chemical name.
• Common name and synonyms.
• Chemical Abstracts Service (CAS) number and other unique identifiers.
• Impurities and stabilizing additives, which are themselves classified and which contribute to
the classification of the chemical.
Mixtures
• Same information required for substances.
• The chemical name and concentration (i.e., exact percentage) of all ingredients which are
classified as health hazards and are:
° Present above their cut-off/concentration limits or
° Present a health risk below the cut-off/concentration limits.
• The concentration (exact percentages) of each ingredient must be specified except
concentration ranges may be used in the following situations:
° A trade secret claim is made,
° There is batch-to-batch variation, or
° The SDS is used for a group of substantially similar mixtures.
Chemicals where a trade secret is claimed
• A statement that the specific chemical identity and/or exact percentage (concentration) of
composition has been withheld as a trade secret is required.
Section 4
The required information consists of:
• Necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact,
and ingestion).
• Description of the most important symptoms or effects, and any symptoms that are acute or
delayed.
• Recommendations for immediate medical care and special treatment needed, when necessary.
Section 5
The required information consists of:
• Recommendations of suitable extinguishing equipment, and information about extinguishing
equipment that is not appropriate for a particular situation.
• Advice on specific hazards that develop from the chemical during the fire, such as any
hazardous combustion products created when the chemical burns.
• Recommendations on special protective equipment or precautions for firefighters.
Section 6
The required information may consist of recommendations for:
• Use of personal precautions (such as removal of ignition sources or providing sufficient
ventilation) and protective equipment to prevent the contamination of skin, eyes, and clothing.
• Emergency procedures, including instructions for evacuations, consulting experts when
needed, and appropriate protective clothing.
• Methods and materials used for containment (e.g., covering the drains and capping
procedures).
• Cleanup procedures (e.g., appropriate techniques for neutralization, decontamination, cleaning
or vacuuming; adsorbent materials; and/or equipment required for containment/clean up).
Section 7
The required information consists of:
• Precautions for safe handling, including recommendations for handling incompatible
chemicals, minimizing the release of the chemical into the environment, and providing advice
on general hygiene practices (e.g., eating, drinking, and smoking in work areas is prohibited).
• Recommendations on the conditions for safe storage, including any incompatibilities. Provide
advice on specific storage requirements.
Section 8
The required information consists of:
• OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial
Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limit used or
recommended by the chemical manufacturer, importer, or employer preparing the safety data
sheet, where available.
• Appropriate engineering controls (e.g., use local exhaust ventilation, or use only in an enclosed
system).
• Recommendations for personal protective measures to prevent illness or injury from exposure
to chemicals, such as personal protective equipment (PPE) (e.g., appropriate types of eye, face,
skin or respiratory protection needed based on hazards and potential exposure).
• Any special requirements for PPE, protective clothing or respirators (e.g., type of glove material,
such as PVC or nitrile rubber gloves; and breakthrough time of the glove material).
Section 9
The minimum required information consists of:
• 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; • Partition coefficient: n-octanol/water;
• Flash point; • Auto-ignition temperature;
• Evaporation rate; • Decomposition temperature; and
• Flammability (solid, gas); • Viscosity.
The SDS may not contain every item on the above list because information may not be relevant or is not available. When this occurs, a notation to that effect must be made for that chemical property. Manufacturers may also add other relevant properties, such as the dust deflagration index (Kst) for combustible dust, used to evaluate a dust’s explosive potential.
Section 10
The required information consists of:
Reactivity
• Description of the specific test data for the chemical(s). This data can be for a class or family of the chemical if such data adequately represent the anticipated hazard of the chemical(s), where available.
Chemical stability
• Indication of whether the chemical is stable or unstable under normal ambient temperature and conditions while in storage and being handled.
• Description of any stabilizers that may be needed to maintain chemical stability.
• Indication of any safety issues that may arise should the product change in physical appearance.
Other
• Indication of the possibility of hazardous reactions, including a statement whether the chemical will react or polymerize, which could release excess pressure or heat, or create other hazardous conditions. Also, a description of the conditions under which hazardous reactions may occur.
• List of all conditions that should be avoided (e.g., static discharge, shock, vibrations, or environmental conditions that may lead to hazardous conditions).
• List of all classes of incompatible materials (e.g., classes of chemicals or specific substances) with which the chemical could react to produce a hazardous situation.
• List of any known or anticipated hazardous decomposition products that could be produced because of use, storage, or heating. (Hazardous combustion products should also be included in Section 5 (Fire-Fighting Measures) of the SDS.)
Section 11
The required information consists of:
• Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact).
The SDS should indicate if the information is unknown.
• Description of the delayed, immediate, or chronic effects from short- and long-term exposure.
• The numerical measures of toxicity (e.g., acute toxicity estimates such as the LD50 (median
lethal dose)) - the estimated amount [of a substance] expected to kill 50% of test animals in a
single dose.
• Description of the symptoms. This description includes the symptoms associated with
exposure to the chemical including symptoms from the lowest to the most severe exposure.
• Indication of whether the chemical is listed in the National Toxicology Program (NTP)
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 found
to be a potential carcinogen by OSHA.
Sections 12-15 are not regulated by MIOSHA. Check with the Michigan Department of Environmental Quality (DEQ) for any employee training requirements for these sections. DEQ Environmental Assistance Center can be reached at (800) 662-9278 from 8 a.m. to 4:30 p.m., Monday through Friday or email: [email_address]
Section 16, Other information, includes the date of preparation or last revision.
*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).
See Appendix D of 1910.1200 for a detailed description of SDS contents.
HMIS and NFPA secondary container labeling systems guidance might appear in this section of the SDS.
MIOSHA Act 154 requires that posters noting the location and receipt of new or revised SDSs be placed in the work area.
Act 154 will be revised to be in compliance with GHS/Haz Com changes. This change may take some time to be effective.
This slide pictures the posters as they will appear with the anticipated change in wording from MSDS to SDS.
Employers must provide facility specific instruction to employees as described on this slide and the next slide to be compliant with the Haz Com training requirements.
Employers must also maintain and periodically review the written Haz Com program for the facility which contains all of the information on this slide and the next slide.
Employee training requirements have been met if the employer has provided the contents of this training program including the facility specific supplemental training.
This slide highlights some of the additional resources available on the Federal OSHA website.
OSHA Haz Com Web Page: www.osha.gov/dsg/hazcom/index.html
OSHA Guide to GHS: www.osha.gov/dsg/hazcom/ghs.html
This slide highlights some of the additional resources available on the MIOSHA website.
State-wide Outreach seminars will be held. Additional details can be found on the MIOSHA CET training calendar
http://www.michigan.gov/lara/0,4601,7-154-61256_11407_15317-40999--,00.html
The link to the CET DVD lending library is
http://www.michigan.gov/lara/0,4601,7-154-61256_11407_30453-40855--,00.html