A few months ago an entirely preventable tragedy occurred when a UCLA research assistant was burned over 43% of her body and died eighteen days later in a hospital burn unit. Using a plastic syringe to extract a small amount of t-butyl lithium—a chemical compound that ignites instantly when exposed to air—she was engulfed in a flash fire when the syringe came apart in her hands.1 The accident was attributed to poor technique, improper method, poor training, and a lack of supervision. A quick glance at the compound’s MSDS might have prevented this terrible loss.
Loyal readers might recall our February/March 2009 article on planning chemical management for the forensic laboratory. And those folks with total recall might remember that a good system for chemical management begins with a complete inventory of the laboratory’s chemicals and a collection of MSDS for those materials. This column explains what an MSDS is, what information it contains, and how to best use that information.
MSDS is an acronym for material safety data sheet. The purpose of the MSDS is to inform chemical users of the hazards potentially encountered with their use. Both the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) have published regulations dealing with MSDS. However, most chemical products packaged for consumers and general household uses are exempt from these requirements. We will focus on the OSHA regulation as it applies to all employers and their workplaces. Let us begin first with a little history.
MSDS History and Regulations
In the 1940s the Chemical Manufacturers Association (CMA) began producing Chemical Safety Data Sheets for many chemicals used in commerce. These were very detailed in their coverage; the longest of which was some 46 pages. CSDS are no longer produced or supported by the CMA.
In 1985, the OSHA Hazard Communication Standard (29 CFR1910.1200)2 became effective requiring manufacturers and distributors to provide MSDS to their customers. In 1987 this was expanded to “all employers with employees exposed to hazardous chemicals in their workplaces.” The OSHA definition of a hazardous chemical is broad—“any chemical which is a physical hazard or a health hazard.”We do not know many chemicals that would not fall into that definition, do you?
Although the hazard communication standard (HCS) does not require a particular format for the MSDS it does specify what information must be included. Since the HCS does not specify a format for MSDS wide variation existed in the order and completeness of the required information by the many different manufacturers and distributors. Recognizing this problem, the CMA worked on developing a voluntary guidance document in an effort to improve the completeness, accuracy, and consistency of MSDS. In 1993 the “American National Standard for Hazardous Industrial Chemicals—Material Safety Data Sheets—Preparation” (ANSI Z400.1-1993)3 was published establishing an MSDS format containing 16 sections.
The ANSI Z400.1 format for MSDS incorporates all the information required under the OSHA Hazard Communication Standard (plus a few extras). The ANSI format lists sections in a logical sequence and has gained acceptance by most manufacturers and distributors. Thus, our discussion and comments on MSDS content will follow the ANSI design.