Introduction
As part of its responsibility to protect workers and inform them of hazards in their workplace, the Federal Occupational Safety and Health Administration (OSHA) has enacted a broad hazard communication effort. The officially designated way of informing workers who manufacture, transport and use hazardous materials about the specific hazards involved is by the Material Safety Data Sheet (MSDS). There is a minimum amount of information required on each MSDS organized in a specific way so that it is easily accessible to the workers who use or transport the material.
MSDS preparation is matter of knowing the regulatory requirements, some training, having chemical and technical judgment and knowing where to find the information. If you are trained in chemistry you likely will be comfortable handling the kind of information needed for an MSDS. It is a complex area, full of jargon and acronyms and must be approached in an organized, systematic way. If you do not want to attempt such a task there are many MSDS preparation services available. They will likely ask for the formulation data, your current MSDS (if you have one) and MSDSs from your raw material suppliers. Current fees run about $500 to over $1000 for each MSDS depending on the complexity of the material.
Since OSHA specified only the required information and not the exact format, many different formats arose, leading to inconsistency and some confusion. In 1993, the American National Standard for Hazardous Industrial Chemicals - Material Safety Data Sheets - Preparation, ANSI Z400.1 was developed to address the need for a MSDS format that was comprehensive, understandable and consistent. ANSI Z400.1-1993 introduced a standardized 16-section MSDS format. The standard was revised in 1998, 2004 and 2005. The advantages of the new 16-section format became apparent and OSHA now recommends, but does not require, this format. The sections, their purposes and contents are summarized below.
Sections
1. Identification - meaning identification of the product by brand name, trade names, catalog number, synonyms or generic names as well as identification of the manufacturer or importer. The manufacturer must provide a mailing address and business phone numbers. An emergency phone number must be provided that is answered 24 hours a day in case of spills or releases during use or transport. Large companies might staff their own number to handle hundreds or thousands of products but this function can be outsourced to a company that specializes in this service. Smaller companies wanting to comply with this requirement can also employ such a service for $500 - $1000/year or more depending on the number of products covered and number of calls expected.
2. Hazard Identification - this section is a brief summary of the hazards involved and is divided into four subsections. emergency overview, OSHA regulatory status, potential health effects and potential environmental effects. The emergency overview subsection provides a physical description of the material and the most important effects on health and environment. The OSHA status subsection indicates whether the material is hazardous or non-hazardous according to the OSHA standard. The potential health effects subsection gives effects and symptoms of exposure and target organs and physiological systems affected. The Potential Environmental Effects subsection describes the effects expected from release of the material into the environment.
3. Composition/Information on Ingredients - this is ideally a list of all the components although there is no requirement to disclose non-hazardous substances. Any substance deemed to be hazardous by OSHA that is present in amounts of 1% or greater in your product must be disclosed on this list. If it is listed as a carcinogen, then it must be disclosed if present in amounts of 0.1% or greater. The amount of each component listed is given as a percentage or a range. Exposure limits are given for each component listed. The required limits are the OSHA Permissible Exposure Limits (PEL) and the Threshold Limit Value (TLV) or Ceiling by the American Congress of Governmental Industrial Hygienists. These are published on lists and may have the units of parts per million (ppm) or of milligrams per cubic meter (mg/m3). Other designations you might see in this data are Time-Weighted Average (TWA), Short-Term Exposure Limit (STEL) and Immediate Danger to Life and Health (IDLH).
4. First-aid Measures - has two subsections. The first aid part lists the immediate actions to take by any responder for exposure by ingestion, skin or eye contact or by inhalation. The second subsection, called Notes to Physicians, included specific information regarding antidotes, specific treatments and diagnostic procedures and the like about the material.
5. Fire-fighting Measures - highlights any special needs or situations to avoid for firefighters
6. Accidental Release Measures - provides procedures for cleaning up both small and large spills to minimize the impact on people, property and the environment. Certain chemicals have specific reporting requirements for spills and releases.
7. Handling and Storage - directs the safe handling and storage of the material. Precautions appropriate and specific for the unique properties of the material should be emphasized.
8. Exposure Controls/Personal Protection - is now divided into three subsections. The first contains established exposure guidelines for the material or components. The various types of data were discussed back in Section 3. Subsection 2 provides guidance on personal protective equipment (PPE) such as eye/face protection, gloves and clothing for skin protection, respiratory protection and general hygiene considerations. This may also indicate if a hood, glovebox or extra ventilation is needed as well as the type of shower or eyewash facility that should be available. Administrative controls such as preplacement and periodic medical exams or any engineering controls that may be appropriate to help minimize the hazards are discussed in subsection 3.
9. Physical and Chemical Properties that are pertinent to proper identification, safe handling and minimizing hazards such as appearance, odor, odor threshold, physical state, pH, melting/freezing point, initial boiling point and boiling range, flash point, evaporation rate, flammability (solid, gas), upper/lower flammability or explosive limits, vapor pressure, vapor density, specific gravity or density, solubility, partition coefficient: n-octanol/water, auto-ignition temperature and decomposition temperature. Some of these are not applicable or not available, but data that is readily available should be presented.
10. Stability and Reactivity - any special reactivities or instabilities are addressed here. Chemical stability, conditions to avoid, incompatible materials, hazardous decomposition products and the possibility of hazardous or uncontrolled reactions are included.
11. Toxicological Information - here is the place to insert results of toxicology studies of the relevant substances administered to various mammalian species orally or to skin, eyes or by inhalation. These studies provide an indication of how the substance can be expected to affect people. It is important to understand the terminology used in toxicological studies such as oral, dermal, LD50, LC50 and the units of measurement. The procedure is to administer a set of varying doses of the substance to groups of animals in order to find the dosage that kills half of the subjects in a given time. That amount, usually expressed as ratio of milligrams (mg) of substance to the body weight in kilograms (kg), is considered the LD50 for that particular route. Oral ingestion may have a very different value than the same substance applied to the skin or inhaled. Inhalation of vapors of a material requires a concentration in air rather than a dose of a fixed weight. Studies of effects on eyes are more to gauge the damage to the delicate eye tissue than to try to cause death. This information is likely to be on recent MSDSs for the raw materials, or they can be found in various databases or toxicological references. Other data such as skin and respiratory sensitization, carcinogenicity, neurological effects, genetic effects, reproductive effects, developmental effects may be included in this section also.
12. Ecological Information contains information on the effects the material may have on plants and animals in the environment. Results of studies on various fates of the material, such as bio-persistance or bio-accumulation, ecotoxicity, degradability, mobility in environmental media and other adverse effects may be included.
13. Disposal Considerations section provides information useful for the proper disposal, recycling or reclamation of the material and/or its container. Certain more hazardous chemicals listed in 40 CFR 261 Resource Conservation and Recovery Act (RCRA) must be disposed of as hazardous waste with special procedures and labeling under EPA jurisdiction and this is noted here as well.
14. Transport Information - summarizes the Federal Department of Transportation (DOT) requirements including the proper DOT shipping name, hazard class, packing group, packing procedures, quantity limitations for various modes of transport and reportable quantities for spills and releases.
15. Regulatory Information is a catch-all section for a host of other regulations or statutes that might pertain to specific chemicals and materials. Any other regulatory interest in the components can be summarized here. Some US Federal regulations or agencies shown may include Clean Air Act (CAA), Clean Water Act (CWA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), Drug Enforcement Administration (DEA), Food and Drug Administration (FDA), OSHA, Safe Drinking Water Act (SDWA), Superfund Amendments and Reauthorization Act (SARA) Title III, Toxic Substances Control Act (TSCA) and United States Department of Agriculture (USDA), although this list is not exhaustive.
16. Other Information - is a catch all section for the least urgent information and administrative details. It might have a list of abbreviations or explanations of hazard rating systems. The revision history of the document, the preparer's name and references used in the preparation are other types of information that are common here. There is also generally a legal disclaimer that the document was based on information available at the time and prepared in good faith as a shield against lawsuits arising from errors or omissions.
This is certainly a lot of information that needs to be collected on sometimes 5 or 10 separate substances for many products. But it is a finite amount of information and can be collected by technically oriented people with some training. It is hard sometimes to know how much you don't know, so when in doubt its best to err on the side of caution and employ a professional. This is, after all, supposed to be an authoritative document listing all the known hazards and many potential hazards associated with the product. OSHA tends to overlook minor errors or omissions of data, but major omissions can lead to errors in handling or emergency response. There could be major legal liabilities and business consequences for errors of this kind. Therefore, do not fail to describe fully the major hazards of the material.
