1. 1 More than just a tick (√): What auditors should know about (M)SDSs Claudine Roos Centre for Environmental Management North-West University Potchefstroom Campus Private Bag X6001 POTCHEFSTROOM 2520 Tel: +27 (0) 18 299-1581 Fax: +27 (0) 18 299-4266 E-Mail: 12568473@nwu.ac.za

2. 2 Revision 2010-01 What auditors should know about MSDS’s What is a (M)SDS? Material Safety Data Sheet. SANS 11014:1994/2010  Safety Data Sheet for Chemical Products: Content and order of sections. Referred to as Safety Data Sheets (SDS) according to SANS 10234:2007  Globally Harmonized System (GHS) of classification and labeling of chemicals (GHS). Regulated by the Occupational Health & Safety Act (Act 85 of 1993). © CEM

3. 3 Revision 2010-01 What auditors should know about MSDS’s What is a (M)SDS? © CEM In a group of 23….

4. 4 Revision 2010-01 What auditors should know about MSDS’s What is a (M)SDS? © CEM

5. 5 SANS 10234 – General requirements

6. 6 Revision 2010-01 What auditors should know about MSDS’s General 8.1.1 A SDS shall be produced for all substances and mixtures which meet the criteria for physical, health or environmental hazards and carcinogenic, toxic to reproduction or target organ toxicity in concentrations exceeding the cut-off values/concentration limits specified by the criteria for mixtures. © CEM

7. 7 Revision 2010-01 What auditors should know about MSDS’s General © CEM Hazard classCut-off value (concentration limit) % Acute toxicity Skin corrosion Skin irritation Serious damage to eyes Eye irritation Respiratory sensitisation Skin sensitisation Mutagenicity: Category 1 Category 2 Carcinogenicity Reproductive toxicity Target organ systemic toxicity Single exposure Repeat exposure Hazardous to the aquatic environment ≥ 1,0 ≥ 0.1 ≥ 1,0 ≥ 0.1 ≥ 1.0

8. 8 Revision 2010-01 What auditors should know about MSDS’s General 8.1.1 The competent authority can also require SDSs for mixtures not meeting the criteria but which contain hazardous substances. 8.1.2 Every supplier, manufacturer, importer or distributor of a hazardous substance or mixture shall provide the party receiving such a substance or mixture with an SDS, free of charge. 8.1.3 Any new information on the substance or mixture shall be forwarded to the recipient of the SDS, free of charge. © CEM

9. 9 SANS 10234 - Format

10. 10 Revision 2010-01 What auditors should know about MSDS’s Format Section I:Product & company identification Section II:Composition/Information on ingredients Section III:Hazards identification Section IV:First aid measures Section V:Fire fighting measures Section VI:Accidental release measures Section VII:Handling and storage Section VIII:Exposure controls/Personal protection © CEM

11. 11 Revision 2010-01 What auditors should know about MSDS’s Format Section I:Product & company identification Section II:Composition/Information on ingredients Section III:Hazards identification Section IV:First aid measures Section V:Fire fighting measures Section VI:Accidental release measures Section VII:Handling and storage Section VIII:Exposure controls/Personal protection What is the product & what should be known immediately in an emergency? © CEM

12. 12 Revision 2010-01 What auditors should know about MSDS’s Format Section I:Product & company identification Section II:Composition/Information on ingredients Section III:Hazard identification Section IV:First aid measures Section V:Fire fighting measures Section VI:Accidental release measures Section VII:Handling and storage Section VIII:Exposure controls/Personal protection What should be done in a emergency situation? © CEM

13. 13 Revision 2010-01 What auditors should know about MSDS’s Format Section I:Product & company identification Section II:Composition/Information on ingredients Section III:Hazard identification Section IV:First aid measures Section V:Fire fighting measures Section VI:Accidental release measures Section VII:Handling and storage Section VIII:Exposure controls/Personal protection How can hazardous situations be prevented? © CEM

14. 14 Revision 2010-01 What auditors should know about MSDS’s Format Section IX:Physical and chemical properties Section X:Stability and reactivity Section XI:Toxicological information Section XII:Ecological information Section XIII:Disposal considerations Section XIV:Transportation information Section XV:Regulatory information Section XVI:Other information © CEM

15. 15 Revision 2010-01 What auditors should know about MSDS’s Format Section IX:Physical and chemical properties Section X:Stability and reactivity Section XI:Toxicological information Section XII:Ecological information Section XIII:Disposal considerations Section XIV:Transportation information Section XV:Regulatory information Section XVI:Other information Any other useful info? © CEM

16. 16 SANS 10234 - Content

17. 17 Revision 2010-01 What auditors should know about MSDS’s Content Section IX:Physical and chemical properties ©CEM SectionDescriptionRequirements 1Identification of the substance or mixture and of the supplier Product identifier, chemical class & synonym. Other means of identification. Recommended use. Supplier’s details. Details of person preparing SDS. Date of SDS preparation (valid for 3 years). 2 Composition/ information on ingredients Chemical identity and CAS no. of hazardous ingredients. Composition/ingredient concentrations. Common name, synonyms, etc LD50s and/or LC50s for ingredients. Exposure limits for ingredients. 3Hazards identification Relevant routes of exposure. Adverse health effects from exposure (chronic or acute) to product or ingredients of product. Length of exposure Severity of effect Target organ Type of effect Signs and symptoms

18. 18 Revision 2010-01 What auditors should know about MSDS’s Content Section IX:Physical and chemical properties ©CEM SectionDescription Requirements 4First Aid Measures Description of necessary measures, subdivided according to different routes of exposure. Most important symptoms/effects, acute and delayed. Indication of immediate medical attention and special treatment needed. 5Fire-fighting measures Flash point and method. Ignition temperature and flammability. Sensitivity to explosion by mechanical impact or static discharge. Hazardous combustion products. Fire fighting procedures (extinguishing media). 6 Accidental release measures Personal precautions, protective equipment and emergency procedures. Environmental precautions. Methods and materials for containment and cleaning up.

19. 19 Revision 2010-01 What auditors should know about MSDS’s Content Section IX:Physical and chemical properties ©CEM SectionDescription Requirements 7Handling and storage Precautions for safe handling. Conditions for safe storage, including any incompatibilities. 8Exposure controls Control parameters e.g. occupational exposure limit values or biological limit values. Appropriate engineering controls. Individual protection measures, such as personal protective equipment. 9Physical and chemical properties Appearance (physical state, colour etc). Odour & Odour threshold. pH. Melting point/freezing point/boiling point. Flash point & flammability. Evaporation rate. Upper/lower flammability or explosive limits. Vapour pressure & Vapour density. Relative density. Solubility(ies). Partition coefficient: n-octanol/water Auto-ignition temperature. Decomposition temperature.

20. 20 Revision 2010-01 What auditors should know about MSDS’s Content Section IX:Physical and chemical properties ©CEM 7 SectionDescription Requirements 10Stability and Reactivity Chemical stability. Possibility of hazardous reactions. Conditions to avoid (e.g. static discharge, shock or vibration). Incompatible materials. Hazardous decomposition products. 11Toxicological information Effects of short and long-term exposure Irritancy Sensitization Carcinogenicity Reproductive toxicity Teratogenicity Mutagenicity Name of toxicologically synergistic products 12Ecological information Ecotoxicity (aquatic and terrestrial) Persistence and degradability. Bioaccumulative potential. Mobility and partitioning. Other adverse effects.

21. 21 Revision 2010-01 What auditors should know about MSDS’s Content Section IX:Physical and chemical properties ©CEM 7 SectionDescription Requirements 13Disposal considerations Guidelines on disposal of chemical and packaging. Recommendations are based upon the physical state and hazardous properties of the material. 14Transportation information UN number. UN Proper shipping name. Transport hazard class(es). Packing group, if applicable. Marine pollutant (Yes/No). Special precautions. 15Regulatory information Safety, health and environmental regulations specific for the product in question. 16Other information

22. 22 How is (M)SDSs applicable to auditing?

23. 23 Revision 2010-01 What auditors should know about MSDS’s ISO 14001: 2004 Elements 4.3.1. Environmental Aspects  Procedures to identify aspects of activities, PRODUCTS and services.  Determine significant impacts.  Were the information (toxicological and ecotoxicological) as specified in Sections 11 and 12 of the (M)SDS taken into account during the risk assessment?  Significance rating of hazards.  Consequences of loss of containment/spillage.  Controls or mitigation measures. © CEM

24. 24 Revision 2010-01 What auditors should know about MSDS’s ISO 14001: 2004 Elements 4.3.2. Legal and other requirements  Must have procedures in place to:  Identify and have access to requirements.  Determine how these requirements apply to its environmental aspects.  Take legal and other requirements into account in the EMS. 4.3.3. Objectives and targets  Take other requirements into account when establishing objectives and targets. © CEM

25. 25 Revision 2010-01 What auditors should know about MSDS’s ISO 14001: 2004 Elements 4.4.2. Competence, Training and Awareness  Education, training or experience of persons having the potential to cause significant environmental impacts.  Use of (M)SDS.  Meaning of relevant sections.  Consequences of departure from specified procedures. 4.4.5. Control of documents  Approval of (M)SDS for adequacy.  Correct sections and content.  Identifiable.  Accessible. © CEM

26. 26 Revision 2010-01 What auditors should know about MSDS’s ISO 14001: 2004 Elements 4.4.6. Operational Control  Documented procedures.  Operating criteria.  Communication of procedures.  Was the contents of the (M)SDS taken into account? 4.4.7. Emergency Preparedness and Response  Procedures to identify emergency situations.  Response.  Test emergency procedures.  Sections 4 and 6 of (M)SDS? © CEM

27. 27 Model questions

28. 28 Revision 2010-01 What auditors should know about MSDS’s (M)SDSs and auditing Required for Occupational Health and Safety purposes – in terms of the Occupational Health and Safety Act (85 of 1993).  Are concentrations to which employees are exposed below the recommended exposure limit?  Do employees follow the correct procedures and wear the correct PPE as specified by the (M)SDS?  Are handling and storage, disposal and transportation measures as specified in the (M)SDS adhered to? © CEM

29. 29 Revision 2010-01 What auditors should know about MSDS’s (M)SDSs and auditing  Were the information on the (M)SDS considered when:  Determining significant environmental aspects?  Determining objectives, targets and programmes?  Developing operational controls?  Developing Emergency plans? © CEM

30. 30 Revision 2010-01 What auditors should know about MSDS’s (M)SDSs and auditing Monitoring and measurement:  Are the concentrations of the substance released to land, air or water below the limits suggested by the (M)SDS?  Refer to Sections 3, 11 and 12.  Can refer to LD and LC50-values.  Also, IC or EC50-values.  LOEC (lowest observed effect concentration).  NOEC (no observed effect concentration). © CEM

31. 31 Revision 2010-01 What auditors should know about MSDS’s (M)SDSs and auditing Other questions applicable to (M)SDSs:  Is the (M)SDS company/product specific?  Ie. If you have a product from company A the (M)SDS should be from company A.  Is the (M)SDS still valid?  Needs to be revised every 3 years.  Is the (M)SDS stored in a location that is easily accessible?  Are relevant personnel and emergency responders trained on the content of the (M)SDS? © CEM

32. 32 Conclusions

33. 33 Revision 2010-01 What auditors should know about MSDS’s Conclusions (M)SDSs are extremely USEFUL, but rarely used tools. It contains information that can ENHANCE Occupational Health and Safety and Environmental Management Systems. It does not only instruct how to respond in an emergency situation, but may also AVOID incidents – if incorporated into the EMS and Risk Assessments. © CEM