The Safety Guys: Making Sense of MSDS--The Foundation of Safe Chemical Management
By: Vince McLeod, CIH and Glenn Ketcham, CIH
Issue: June/July 2009
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.
MSDS Content
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.
Section 1: Chemical Product and Company Identification
The contents of this section are obvious: the chemical and/or product are named here along with the manufacturer or distributor and should include the company mailing address and telephone number. A key to this section is that it should relate the MSDS to the container label and shipping documents. Other useful information that is usually included is a brief description of the chemical or product and its general use. Most companies will also give the date the MSDS was written or the date it was last revised.
Section 2: Composition, Information on Ingredients
This important section identifies the hazardous components and amounts of each for the product. This is where you look to see what you are dealing with. The chemical abstract service (CAS) number should be given as this number provides positive identification of each component. The CAS number is important with the many different naming conventions and pseudonyms in use. This section also provides information on published exposure limits, if applicable, such as OSHA permissible exposure limits (PEL), American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit values (TLV), and others like IDLH (immediately dangerous to life and health) limits. If any of the components or their amounts are trade secrets that must be stated here.
Section 3: Hazards Identification
The material’s appearance, odor, and health, physical, and environmental hazards are listed in this section. The information here expands on the previous section providing details on each component’s hazards, routes of exposure, symptoms for both acute and chronic exposures, and target organs for each exposure route. Information on flammability, reactivity, and proper personal protective equipment should also be given.
Section 4: First Aid Measures
Instructions on emergency and first aid procedures are provided for each potential route of exposure, e.g. inhalation, ingestion, skin, or eye contact. They should be concise and written in easily understood layman’s language. If there are specific medical steps then a “Notes to Physician” section is provided for this information.
Section 5: Fire Fighting Measures
Described here are the fire and explosive properties of the chemical or product components. The proper extinguishing media is given along with any special protective equipment needed and unusual decomposition hazards. Additional information such as flashpoint, autoignition temperature, and flammable limits in air are helpful depending on the chemical components.
Section 6: Accidental Release Measures
Addressed in this section are the proper responses to any spill or leak of the material. The information presented is usually intended for emergency response personnel. It describes the personal protective equipment needed, any special precautions such as ventilation or evacuation, clean up methods, and environmental precautions.
Section 7: Handling and Storage
This section and the following one are very important for laboratory personnel and chemical managers. This section contains guidance for minimizing potential hazards while handling and storing the material. Addressed here are requirements for types of containers and dispensing equipment as appropriate. Conditions to avoid, such as temperature extremes, secondary containment, as well as work and hygiene practices should also be covered here.
Section 8: Exposure Controls, Personal Protection
Discussed in this section are the engineering controls and personal protective equipment (PPE) to be used when handling the material. The need for any ventilation or special exhaust systems is covered along with requirements for eyewash and safety showers. Laboratory personnel should focus on PPE instructions which provide proper eye, hand, and body protection and when respiratory protection is needed.
Section 9: Physical and Chemical Properties
Of particular interest to chemists, the information presented here assists users in determining proper PPE, handling, and storage. General appearance, odor, physical state (liquid, solid, or gas) are given in addition to pH, vapor pressure and density, specific gravity, boiling point, and others depending on usefulness. Any warning properties (i.e. how to detect the substance via smell, taste, or feel) should be well noted.
Section 10: Stability and Reactivity
Although more important for emergency responders, users should also be familiar with the information in this section which depicts potentially hazardous reactions or decomposition products. Examples include evolution of hazardous gases or production of heat if involved in a fire. Any incompatibilities that could lead to hazardous conditions should also be discussed here.
Section 11: Toxicological Information
Information listed in this section is drawn from both animal testing and human experience and should include all known toxicities of the material. Included are both acute and chronic effects on skin, eyes, immune system, and reproductive system as well as from inhalation or ingestion. Data on irritancy, sensitization, and carcinogenicity should also be stated.
Section 12: Ecological Information
Potential impacts should the product be released to the environment are presented here. Data on the expected environmental fate and whether or not degradation occurs is given along with effects on plant, animal, and aquatic life.
Section 13: Disposal Considerations
Guidance given here is intended for use by technical people in evaluating waste treatment options and those responsible for waste management. Usually reference is made to follow all applicable federal, state, and local regulations.
Section 14: Transport Information
This section provides information for shipping the material. In general this means following the U.S. Department of Transportation (DOT) regulations contained in 49CFR172 and includes listing the proper shipping name, hazard classification number and description, UN identification number, proper labeling, and North American Emergency Response Guidebook number as applicable. Information on international shipping may also be given.
Section 15: Regulatory Information
The chemical or product’s regulatory status is presented in this section. Included are the reporting requirements, threshold planning quantities, release reporting quantities, and inventory status under the U.S. Superfund Amendments and Reauthorization Act (SARA), Comprehensive Environmental Response, Compensation, and Liability Act CERCLA, Toxic Substances Control Act (TSCA) and other federal and state regulations as applicable.
Section 16: Other information
This section is intended for material that does not fit into any of the preceding sections yet the preparer feels is pertinent. Usually included are the preparer’s name and contact information, revision dates, references, and definitions of terms and acronyms.
As you can see now, MSDS are complex and take some work to understand. But if you make the effort to get to know the layout and information they contain, they can provide valuable information and be a reliable asset that you turn to in time of need.
American National Standard for Hazardous Industrial Chemicals — Material Safety Data Sheets — Preparation, ANSI Z400.1-1993. New York, American National Standards Institute, 1993.
Vince McLeod is a Certified Industrial Hygienist by the American Board of Industrial Hygiene and has 20 years of experience in all facets of occupational health and safety and specializes in hazard evaluation and exposure assessments.
Glenn Ketcham is a Certified Industrial Hygienist with 25 years experience in the health and safety field. He is currently the Risk Manager for the University of Florida (UF) with responsibility for the general liability and insurance programs, loss prevention, ergonomics, emergency management, and the occupational medicine surveillance program.
