Hazard Communication Program

Oregon OSHA Online Course 205

This material is for training purposes only. Its purpose is to inform Oregon employers of best practices in occupational safety and health and general Oregon OSHA compliance requirements. This material is not a substitute for any provision of the Oregon Safety Employment Act or any standards issued by Oregon OSHA. For more information on this online course and other OR-OSHA online training, visit the Online Course Catalog.

MODULE 4: MATERIAL SAFETY DATA SHEETS (MSDS)

INTRODUCTION

The Material Safety Data Sheet (MSDS) is used to communicate chemical hazard information from the manufacturer to the employee. This is the information needed to inform and train employees on the safe use of hazardous chemicals. The employer is required to have an MSDS for each hazardous chemical product they use. This module will examine the MSDS and the requirements for maintaining an effective MSDS system. So, let's get going.

Who must have them?

• Chemical manufacturers and importers must obtain or develop a material safety data sheet for each hazardous chemical they produce or import.
• Employers must have a material safety data sheet in the workplace for each hazardous chemical which they use.

The MSDS form

Let's take a look at the MSDS form, itself. Some of the terms in each section link to additional information. You can check out the glossary for general information on terms you may not be familiar with. I'll detail important points related to each MSDS section and then show you an example that illustrates those points. So, let's start the review.

Each material safety data sheet must be in English (although the employer may maintain copies in other languages as well), and must contain at least the following information:

The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.

The English language requirement was included to prevent importers of chemicals from supplying MSDSs in a foreign language. This requirement, however, does not prevent a chemical manufacturer/employer from translating MSDSs from English into foreign languages, in order to assist non-English speaking employees with training comprehension and hazard recognition.

• The identity used on the label;

  
  

• If the hazardous chemical is a single substance, its chemical and common name(s);

  
  

• If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common name(s) of the ingredients which contribute to these known hazards, and the common name(s) of the mixture itself; or,

  
  

• If the hazardous chemical is a mixture which has not been tested as a whole, the chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition (0.1% for carcinogens);

• Physical and chemical characteristics of the hazardous chemical (such as vapor pressure, flash point);

• The physical hazards of the hazardous chemical, including the potential for fire, explosion, and reactivity;

• The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical;

  
  

• The primary route(s) of entry;

  
  

• Emergency and first aid procedures;

  
  

• The OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the material safety data sheet, where available;

  
  

• Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Annual Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions), or by OSHA;

• Any generally applicable precautions for safe handling and use which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks;

• Any generally applicable control measures which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, such as appropriate engineering controls, work practices, or personal protective equipment;

• The date of preparation of the material safety data sheet or the last change to it.

If no relevant information is found for any given category on the material safety data sheet, the chemical manufacturer, importer or employer preparing the material safety data sheet must mark it to indicate that no applicable information was found.

MSDS Management

Here are some more important requirements manufacturers, importers and distributors must meet:

The manufacturer or importer must:

• Prepare one MSDS that applies to all similar mixtures where complex mixtures have similar hazards and contents (i.e. the chemical ingredients are essentially the same, but the specific composition varies from mixture to mixture),
• When preparing the material safety data sheet, ensure that the information recorded accurately reflects the scientific evidence used in making the hazard determination.
• When aware of any significant new information regarding the hazards of a chemical, or ways to protect against the hazards, this new information, add it to the material safety data sheet within three months.
• If the chemical is not currently being produced or imported, add any new information to the material safety data sheet before the chemical is introduced into the workplace again.
• Provide an appropriate material safety data sheet with the initial shipment, with the first shipment after a material safety data sheet is updated, and as requested by the employer or distributor;
• Provide material safety data sheets with the shipped containers or send them to the distributor or employer prior to or at the time of the shipment;

Distributors must:

• Ensure that material safety data sheets, and updated information, are provided to other distributors and employers with their initial shipment and with the first shipment after a material safety data sheet is updated;

  
  

• Either provide material safety data sheets with the shipped containers, or send them to the other distributor or employer prior to or at the time of the shipment;

  
  

• Retail distributor selling hazardous chemicals to employers having a commercial account -- provide a material safety data sheet to such employers upon request, and must post a sign or otherwise inform them that a material safety data sheet is available. If an employer without a commercial account purchases a hazardous chemical from a retail distributor not required to have material safety data sheets on file (i.e., the retail distributor does not have commercial accounts and does not use the materials), the retail distributor must provide the employer, upon request, with the name, address, and telephone number of the chemical manufacturer, importer, or distributor from which a material safety data sheet can be obtained. Chemical manufacturers, importers, and distributors need not provide material safety data sheets to retail distributors that have informed them that the retail distributor does not sell the product to commercial accounts or open the sealed container to use it in their own workplaces.

  
  

• Wholesale distributor selling hazardous chemicals to employers over-the-counter -- provide material safety data sheets upon the request of the employer at the time of the over-the-counter purchase, and post a sign or otherwise inform such employers that a material safety data sheet is available.

  
  

• Distributors and employers who in good faith choose to rely upon the MSDSs provided to them by the chemical manufacturer/importer assume no responsibility for the content and accuracy of the MSDSs.

  
  

What about employer responsibilities?

Employers must obtain a MSDS from the chemical manufacturer or importer as soon as possible if the material safety data sheet is not provided with a shipment that has been labeled as a hazardous chemical.

Employers must maintain in the workplace copies of the required material safety data sheets for each hazardous chemical, and must ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access, microfiche, and other alternatives to maintaining paper copies of the material safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)

Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the material safety data sheets may be kept at the primary workplace facility. In this situation, the employer must ensure that employees can immediately obtain the required information in an emergency.

Employees who work at more than one site during the work shift must be able to obtain MSDS information immediately in an emergency. MSDSs may be kept at the primary workplace facility, as long as the employer has a representative available at all times to ensure ready access to this information. This is the only situation in which an employer is allowed to transmit hazard information via voice communication. The employer must address in the written hazard communication program how MSDS information will be conveyed to remote worksites.

Material safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals.

However, the employer must ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in in their work area(s). Usually, MSDSs will be kept at the "Right to Know" station in a centralized location where most of the work is being accomplished. Along with the MSDSs, there must be a list of chemicals with an effective reference system to help the employee quickly locate a specific MSDS.

Last words

Well, I hope you understand the MSDS and the various requirements related to its management. As usual, read the rules and ask an Oregon OSHA technical services representative or consultant if you have specific questions about MSDS management at your workplace. Now it's time for the quiz, so let's go.

MODULE Quiz

31. According to the text, employers must have a material safety data sheet in the workplace for each hazardous chemical which they _______.

a. use
b. store
c. sell
d. replace

32. What is the basis for the English language requirement for the MSDS?

a. To make sure only domestic manufacturers produce the MSDS.
b. To prevent importers of chemicals from supplying MSDSs in a foreign language.
c. To prevent the proliferation of MSDS in multiple languages.
d. To encourage all employees to learn English.

33. Distributors and employers who in good faith choose to rely upon the MSDSs provided to them by the chemical manufacturer/importer assume no responsibility for the content and accuracy of the MSDSs.

a. True
b. False

34. Employers with workers at more then one worksite may keep MSDSs at a centralized location as long as _________:

a. an employer representative is available
b. employees have ready access
c. the employer addresses how information is conveyed
d. all of the above

35. Material safety data sheets may be kept ________________, including operating procedures.

a. in any form
b. only in hard copy format
c. on a computer
d. only as a 13-section document

36. Material safety data sheets may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals.

a. True
b. False

37. Alternatives to maintaining paper copies of the material safety data sheets are permitted as long as there are _______________:

a. written procedures to access information
b. 20 or more hazardous chemicals on site
c. no barriers to immediate employee access
d. paper copy backups

38. The employer must ensure required information is provided for only the most hazardous chemicals.

a. True
b. False

39. MSDSs must be readily accessible during each work shift to employees when they are __________:

a. potentially exposed
b. in their work area(s)
c. exposed to the chemical
d. in the workplace

40. Usually, MSDSs will be kept at the "Right to Know" station in __________ where most of the _______ is being accomplished.

a. an administrative office, management
b. a supervisors, oversight
c. the maintenance shop, repair
d. a centralized location, work