Spotlight on OSHA Inspection Procedures for Safety Data Sheets

In the recently revamped Inspection Procedures for the Hazard Communication Standard compliance directive, OSHA explains to its inspectors how to review Safety Data Sheets.

Inspectors are tasked to look for the following, in a section by section breakdown of the SDS:

Section 1- Identification

The SDS requires the inclusion of the contact information for the manufacturer in addition to emergency contact numbers. There is no requirement for the emergency number to be staffed 24 hours per day if the SDS specifies the restrictions on the contact hours. The emergency contact number can be for a company contracted to provide information in the case of an emergency(e.g., Chemtrec).

There must be someone available at the emergency phone number who is able to provide more information concerning the product.

Section 2– Hazard(s) identification

The classification must include the class and the category, e.g.,Flammable Liquid, Category 1.

Hazard not otherwise classified (HNOC)

HNOC must be listed in section 2 of the SDS. As HNOCs are identified through the 1910.1200(d) hazard classification process, it is permissible to include information on HNOCs under subheading (a).

The manufacturer, importer or distributor may include hazard symbols on the label or SDS for HNOCs as long as that symbol is not an HCS 2012 pictogram and does not contradict or cast doubt on the information that is required.

Precautionary statements are not required for combustible dust hazards and, therefore, none are required in section 2 of the SDS if combustible dust is the only hazard listed.

Pictograms/symbols

Appendix D of the HCS, section 2, states, “Hazard symbols may be provided as graphical reproductions in black and white or the name of the symbol, e.g., flame, skull and crossbones.” The hazard symbol is the symbol inside the frame of the pictogram. Therefore, just the symbol can be used or the name of the symbol can be used.

If the pictogram is used, it may be printed in black and white.

If additional information is added to the required hazard statements or precautionary statements on the label, it is consistent to include that language on the SDS.

Responsible parties may add their own precautionary statements to section 2 of the SDS so long as they are relevant and do not contradict or cast doubt on the validity of the other information in the SDS.

Responsible parties may include rating systems (e.g., HMIS, NFPA) in section 2 of the SDS as long as they do not contradict or cast doubt on the HCS 2012 classification.

Section 3–Composition/information on ingredients.

If a component may be released to create airborne concentrations above an OSHA PEL or an ACGIH TLV®, it is considered a health hazard and must be included on the SDS.

Section 8–Exposure controls/personal protection.

The requirement to include PELs and TLVs® in section 8 of the SDS applies to any constituent or ingredient (including additives and impurities) that is present in the mixture or substance above its cut-off value, or if it is below the cut-off value but still contributes to the hazard classification of the mixture.

The list of constituents in sections 3 and 8 must be the same.

If a constituent does not have a PEL or TLV®, its exposure limit must be listed as “not applicable (N/A)” or “none.” If the manufacturer, importer, or distributor chooses to list another recommended occupational exposure limit, for example, NIOSH Recommended Exposure Limit (REL), the correct limit must be used or it must say “not applicable (N/A)” or “none.”

It is permissible to state, “The following constituents are the only constituents of the product which have a PEL, TLV or other recommended exposure limit. At this time, the other constituents have no known exposure limits.”

Section 9–Physical and chemical properties.

All the items listed in Section 9 of Appendix D must be present on the SDS. If an item(s) is not applicable then it must be marked with “not applicable (N/A),” or “none.”

If the item is listed in another section (e.g., flash point also listed in section 5) it must still be listed in section 9.

Other physical and chemical properties may also be listed in addition to listed items.

Sections 12-15–Ecological Information; Disposal considerations; and Transport information.

OSHA is not requiring these sections to be filled out; however, the section headings must be present.

Section 16–Other information, including date of preparation or last revision.

This section is officially titled,“Other information, including date of preparation or last revision.” It is acceptable to shorten the title to “Other information” as long as the date of preparation or last revision is listed.