Globally Harmonized System (GHS) Change from Material Safety Data Sheet (MSDS) to Safety Data Sheet (SDS)

Objectives History of GHS Major Changes Under GHS What Do You Need to Do Step by Step Compliance

History of GHS An international mandate to harmonize labels was adopted at the United Nations Conference on the Environment and Development (UNCED) in 1992 in Brazil: A globally-harmonized hazard classification and compatible labeling system, including material safety data sheets and easily understandable symbols, should be available, if feasible, by the year 2000.

In March 2012, Occupational Safety and Health Administration (OSHA) published a final rule to align its Hazardous Communication Standards (HCS) regulations with the Globally Harmonized System (GHS) of Classification and labeling of chemicals

The primary goal of GHS is improved protection of human health and the environment by providing chemical users and handlers with enhanced and consistent information on chemical hazards.

The GHS is based on major existing systems for industrial chemicals, pesticides, consumer chemicals, and chemicals in transport, but implementation of the GHS would require some changes in all existing systems in order to achieve harmonization.

However, it is important for growers who use Federally regulated pesticides to note that the Environment Protection Agency (EPA) has NOT yet moved to amend its pesticide labeling regulations under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to align with the GHS.

Why the switch from MSDS to SDS? Under the HazCom 2012, the MSDS will be replaced with a Safety Data Sheet (SDS).

Why the switch from MSDS to SDS? Before the HazCom 2012, there were several acceptable MSDS formats. OSHA’s adoption of Global Harmonization Standards (GHS) requires the use of a single format. All SDS will have 16 sections that appear in a specific order.

Major Changes Under GHS

Changes MSDS to SDS Format Labeling Requirements/Pictograms Hazard Classification

Changes MSDS to SDS Format MSDS will now be referred to as Safety Data Sheets (SDS). There is now a specified 16-section format that must be followed.

Section 1 Identification of Substance and Supplier Includes Product identifier (Product Name). Manufacturer’s or distributor’s name, address and phone number. Emergency phone number. Recommended use. Restrictions on use.

Section 2 Hazard Identification Includes: All hazards regarding the chemical. Required label elements: Pictograms. Signal Word. Hazard Statements.

Section 2 Hazard Identification Signal Words (OSHA): Warning. Danger.

Section 3 Composition/Information on Ingredients Includes: Composition/information on ingredients: Common Name. CAS number. Concentration. Information on chemical ingredients. Trade secret claims.

Section 4 First Aid Measures Includes: Important symptoms. Acute symptoms. Delayed symptoms. Required treatment based on route of exposure.

Section 5 Firefighting Measures Includes: Suitable extinguishing techniques. Equipment needed. Chemical hazards from fire.

Section 6 Accidental Release Measures Includes: Emergency procedures. Protective equipment. Proper methods of containment and cleanup.

Section 7 Handling and Storage Includes: Precautions for safe handling. Precautions for safe storage. Incompatibilities.

Section 8 Precautions to Control Exposure/ Personal Protection Includes: OSHA’s Permissible Exposure Limits (PELs). Threshold Limit Values (TLVs). Appropriate engineering controls. Personal Protective Equipment (PPE) requirements.

Section 9 Physical and Chemical Properties Includes: Chemical’s characteristics.

Section 10 Stability and Reactivity Includes: Stability of chemical. Chemical characteristics.

Section 11 Toxicological Information Includes: Routes of exposure. Related symptoms. Acute effects. Chronic effects. Numerical measures of toxicity. LD50 values and LC50 values.

OSHA does not regulate sections 12 to 16 since other Agencies (like the EPA) regulate information in these sections.

Section 12 Ecological Information Includes: Eco-toxicity. Mobility. Does it move in air, soil, or water. Degradability. Is it biodegradable. Bioaccumulation.

Section 13 Waste Disposal Consideration Includes: Advise to contact local wasted disposal authority for direction on disposal. Information that directs washing liquids should not be allowed to enter drains. Directions for container disposal. Recommendations for disposal if recycling is not an option.

Section 14 Transportation Information Includes: Proper shipping name. Hazard class. Secondary risk. Identification information. Packing group. Label required. Marine pollutant identification.

Section 15 Regulatory Information For pesticides this is the area where any FIFRA information would be included, for example: “Pesticide Registration: This chemical is a pesticide product registered by the Environmental Protection Agency and is subject to certain labeling requirements under federal pesticide law. These requirements differ from the classification criteria and hazard information required for safety data sheets, and for workplace labels of non-pesticide chemicals. Following is the hazard information as required on the pesticide label:”

Section 16 Other Information Includes: Department issuing SDS. Email address. Training necessary. Reissue date/reason for reissue. General intended use of the product.

Pictograms

Pictograms Health Hazard Carcinogen Respiratory sensitizer Reproductive toxicity Target Organ toxicity Mutagenicity Aspiration toxicity.

Pictogram Flame Flammables Self-Reactives Pyrophorics Self-Heating Emits flammable gas Organic peroxides

Pictograms Exclamation Mark Skin and eye irritant Skin sensitizer Acute toxicity Narcotic effects Respiratory tract irritant

Pictograms Gas Cylinder Gas Under Pressure Flames Over Circle Oxidizer

Pictograms Corrosion Skull and Crossbones Corrosives Damaging Destroys materials Skull and Crossbones Acute Toxicity (Severe)

Pictograms Exploding Bomb Explosives Self-Reactive Organic peroxides

Pictograms Environment Aquatic Toxicity

Hazard Classification The definitions of hazard have been changed to provide specific criteria for classification of health and physical hazards, as well as classification of mixtures These specific criteria will help to ensure that evaluations of hazardous effects are consistent across manufacturers, and that labels and safety data sheets are more accurate as a result

Will the change require that both and MSDS and an SDS be kept for the same product? For compliance with the new OSHA HazCom 2012 regulatory requirements, maintaining both an MSDS and a SDS for the same chemical is not necessary. As the SDS becomes available for individual products, they will replace the existing MSDS. Although there is no requirement to keep the older MSDS once it is replaced with an SDS, a good management practice would be to keep an electronic copy on file, especially if existing stocks of the chemical were purchased under the older MSDS.

Will the change require that both and MSDS and an SDS be kept for the same product? When the chemical in question is a pesticide and the content of the MSDS and the SDS differs, a copy of both documents must be maintained to ensure compliance with OSHA HazCom 2012 and FIFRA which regulates pesticide products.

The differences between EPA’s current requirements and the GHS are related to classification criteria, hazard statements, pictograms, and signal words.

For example, FIFRA pesticide product labels may contain the following signal words: of “Danger-Poison with the skull and crossbones graphic,” “Warning,” or “Caution” depending on the toxicity level of the product, and “Danger” for a product that may be a potential skin or eye irritant.

The GHS uses only two signal words, “Danger” and “Warning.”

How this may cause a problem for example is the label of a chemical that has an oral LD50 of 550 mg/kg bears the signal word “Caution” under current FIFRA labeling practices but would require the signal word “Warning” under the GHS Safety Data Sheet format.

For pesticide products, FIFRA labels approved by EPA pre-empt OSHA’s label requirements, but not the requirements for SDS and worker training (except for certified applicators and agricultural workers for whom EPA has training requirements).

EPA realizes that this may require users of the SDS that are prepared for pesticide products to become familiar with two different systems, at least until the agencies’ requirements are harmonized.

As a result, EPA issued guidance in the April 20, 2012 Federal Register to manufactures so that when changes are made to the SDS to meet the OSHA requirements, the new SDS format will also be in compliance with the pesticide regulations under FIFRA.

Will the change require that both and MSDS and an SDS be kept for the same product? When the chemical in question is a pesticide and the content of the MSDS and the SDS differs, a copy of both documents must be maintained to ensure compliance with OSHA HazCom 2012 and FIFRA which regulates pesticide products.

HazCom 2012 Compliance Dates and Deadlines: There is a 3 year phase in period through 2016

HazCom 2012 Compliance Dates and Deadlines: December 1, 2013 – Employers must train employees on how to read GHS formatted labels and SDS’s. Changes to labels are probably more substantial, however, employees need to understand where to find information on the SDS.

HazCom 2012 Compliance Dates and Deadlines: 2013 – 2015 On an Ongoing Basis – Employers should replace existing MSDSs with new SDSs as they become available. For pesticide products, employers must be sure to determine if there are any differences between the MSDS and SDS. If differences exist, a copy of the MSDS must also be maintained to be in compliance with both HazCom2012 and FIFRA.

HazCom 2012 Compliance Dates and Deadlines: June 1, 2015 – Chemical manufacturers and distributors should have completed their reclassification of chemicals and be shipping GHS formatted SDS and labels with their shipments.

HazCom 2012 Compliance Dates and Deadlines: December 1, 2015 – Distributors have an additional 6 months beyond the June 1, 2015 date to pass along manufacturer labels and SDSs in the older formats. However, beyond December 1, 2015, all MSDSs and labels in the U.S. should be in compliance with HazCom 2012 provisions.

HazCom 2012 Compliance Dates and Deadlines: June 1, 2016 – Employers should be fully compliant with HazCom 2012. That includes making any necessary updates to their HazCom program, training employees on any newly identified chemical hazards (identification of new hazards is likely during the reclassification process chemical manufacturers undertake), and updating SDS libraries and secondary labels.

extension.psu.edu/pested This presentation was created in partnership with the Pesticide Education Program, Penn State Cooperative Extension; and the Pennsylvania Department of Agriculture. For more information on this and other resources, please visit extension.psu.edu/pested Where trade names appear, no discrimination is intended, and no endorsement by Penn State Cooperative Extension is implied. Penn State is committed to affirmative action, equal opportunity, and the diversity of its workforce. © The Pennsylvania State University 2012 November 2012