Material Safety Data Sheets (MSDS)
Occupational Safety and Health Administration (OSHA) HazCom regulations require that MSDS’s be developed and maintained for certain potentially hazardous materials. Chemical manufacturers, importers, and distributors of hazardous chemicals are all required to develop/obtain and provide the appropriate MSDS’s to the purchasers to whom they ship chemicals and other hazardous materials. It is the responsibility of each principal investigator or other person responsible for any specific workplace to obtain and maintain a MSDS for every chemical/material onsite or newly purchased chemical. Once a complete list/inventory has been compiled of the potentially hazardous chemicals in the laboratory/work area, the MSDS files should be checked against the inventory. If any products are missing a MSDS, contact the manufacturer or supplier, and request one (OSHA requires manufacturers to send MSDS’s within 30 days). Most manufacturers and major distributors now have web sites, which allow customers to retrieve or print a MSDS.
MSDS’s must be readily accessible to employees and students when they are in the area where the chemicals are used or stored. As long as employees/students can get the information when they need it, any approach may be used. Laboratories with large numbers of chemicals may computerize the information and provide access through terminals. However, SRS recommends that a hard copy of all MSDS’s be kept in a ring binder with all the other OSHA HazCom documentation. As new chemicals are purchased, the inventory and MSDS’s should be updated on a monthly basis.
Under the OSHA HazCom standard, the role of MSDS’s is to provide detailed information to employees about each hazardous chemical, including its potential adverse physical and health hazards, its physical and chemical characteristics, recommendations for appropriate protective clothing/equipment, OSHA PEL’s, fire hazards, spill cleanup measures, among many other valuable types of information. There is no specific format for the MSDS under OSHA HazCom, although there are specific information requirements. OSHA had first developed a non-mandatory format, OSHA Form 174, but now recommends that the ANSI format be used. The MSDS must be in English.
What is the minimum amount of material that requires an MSDS?
The OSHA HazCom standard does not specify a minimum amount. An early OSHA interpretation once indicated that 2 ounces of ammonia requires an MSDS because this amount would cause injury, but recently another required disclosure of all chemicals which may pose a health risk regardless of the concentration present in the product. Therefore, it would be prudent to request, acquire and maintain a copy of every MSDS provided for any product that may be purchased, for which there is not an exemption.
What items may be exempted from the MSDS requirement?
Exempted are the personal use of articles, food, food additives, alcoholic beverages, cosmetics, drugs and pharmaceuticals, hazardous wastes, tobacco and tobacco products, wood and lumber, office and school supplies, ionizing and non-ionizing radiation, and consumer products. Retail outlets and stores are under no OSHA obligation to distribute MSDS’s for these exempted products/materials to normal consumers. However, use of these “exempted” materials in such quantities as would cause occupational exposure in an employment setting would probably trigger the requirement for the procurement of the MSDS’s by employers, which MSDS’s would then need to be available to employees.