Pesticide Labels & Safety Data Sheets In March 2012, the Occupational Safety and Health Administration (or OSHA) published a final rule to align its Hazard Communication Standard regulations with the Globally Harmonized System of Classification and Labeling of Chemicals (referred to as “GHS”). Two of the driving forces behind these changes were 1.) to comply with the United Nations GHS system used in the workplace; and 2.) to improve worker comprehension of hazards by use of pictograms and signal words on labeling and Safety data sheets. Developed by Carol Black WSU Pesticide Safety Education

Safety Data Sheets Safety data sheets, formerly known as Material Safety Data sheets (or MSDS) describe the hazards of the chemical in more detail than you’ll find on the container label. Safety Data sheets will now have a specified 16-section format that MUST be used by manufacturers, distributors and importers to convey detailed hazard information to the end user. Previously, the MSDS specified what information was required, but the chemical manufacturer or importer could use whatever format or order of information they wanted. Manufacturers, distributors and importers must develop Safety data sheets for all chemicals they sell by June 1st of this year. This same group must make chemical container labels comply with GHS requirements by December 1, 2015.

WARNING SDS signal words Safety data sheets will now also contain Signal words, a single word used to indicate the relative level of severity or hazard and alert the user to a potential hazard on the label. The signal words used are "danger" and "warning." *"Danger" is used for the more severe hazards, *while "warning" is used for less severe hazards. Only one signal word per safety data sheet will be used, no matter how many hazards a chemical has…if one hazard warrants a “Danger” signal word and another corresponds to a “Warning” signal word, only “Danger” will appear on the safety data sheet. These signal words use different toxicity endpoints from pesticide labels – thus they may differ from pesticide label signal words.

Pictograms for hazards Pictograms are meant to communicate specified statements about hazards “Pictogram” means a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical Eight pictograms are designated under this standard for application to a hazard category *Note that (Environment – Aquatic Toxicity) is non-mandatory. Hazard pictograms on SDS always have the red box around them; the skull and crossbones symbol on pesticide labels do not. Pesticide labels use a bee icon and skull and crossbones.

This example Safety Data Sheet shows both the *signal word, DANGER *and two pictograms, an exclamation point because the product causes skin irritation and the flame because the product is highly flammable.

What about pesticide product labels? Under the Global Harmonization System, labels are also changing. However, it is important to note that the Environment Protection Agency has not yet moved to amend its pesticide labeling regulations under the Federal Insecticide, Fungicide, and Rodenticide Act ( or FIFRA) to align with the GHS.

FIFRA pesticide labels US EPA’s FIFRA pesticide product labels are currently not subject to the GHS To date, EPA/OPP has not incorporated the GHS into the FIFRA pesticide classification and labeling regulations Pesticide registrants do not have to update their FIFRA labels to accommodate the GHS To reiterate, EPA’s FIFRA pesticide product labels are currently not subject to the Global Harmonization Standards. *To date, EPA and EPA’s Office of Pesticide Programs has not incorporated the GHS into the FIFRA pesticide classification and labeling regulations *Finally, pesticide registrants do not have to update their FIFRA labels to accommodate the Global Harmonization Standards Pesticide labels are specifically exempted from GHS labeling, but their SDS must comply. EPA and GHS use different hazard endpoints for human health and this is why the do not match.

Signal word issues EXAMPLE For example, If the Safety Data Sheet for a pesticide product conforms to the Globally Harmonized System, elements such as the signal word or certain hazard statements could differ from the pesticide label. For example, some pesticide labels bear the signal word “Caution”, whereas Safety Data Sheets under the Globally Harmonized System use only two signal words, “Danger” or “Warning”

SDS Section 15. Regulatory Information 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: CAUTION Harmful if swallowed Causes moderate eye injury Avoid contact with eyes or clothing This pesticide is toxic to aquatic invertebrates EPA believes that generally explaining why the FIFRA label and the Safety data sheet contain different hazard communication will prevent users from being misled by the inconsistencies. To provide an adequate explanation so the labeling is not misleading, EPA recommends registrants include in their safety data sheets the FIFRA label information and a brief explanation for any differences between that information and the SDS information (example shown here). This information will be found in Section 15, “Regulatory Information” on the Safety Data Sheet.

What are pesticide users required to do? Continue to follow product labels and laws and regulations Continue to comply with OSHA requirements for hazard communication When pesticide suppliers replace MSDS with SDS, employers need to obtain and maintain new SDS for pesticides they use So, What are pesticide users required to do? *Continue to follow product labels and laws and regulations. While FIFRA is the primary law governing the use and application of pesticides, it’s not the primary rule relating to worker-right-to know, transport of hazardous materials, community-right-to know, or fertilizer use and application. *Continue to comply with OSHA requirements for hazard communication. For pesticide products, FIFRA labels approved by EPA pre-empt OSHA’s label requirements, but not the requirements for safety data sheets and worker training. *When pesticide suppliers replace Material Safety Data Sheets with Safety Data Sheets, employers need to obtain and maintain the new Safety Data Sheet for the pesticides they use. Update Safety Data Sheets for products other than pesticides ( like workplace labels) by June 1, 2015