When is an MSDS not an MSDS? When it is an SDS: The GHS and its affect on us
By: Chery F. Kendrick, DVM, MPVM, MLT, ASCP, CFS
One of my New Year’s resolutions was to decrease the paper in my office.So far I have been doing really well at ‘cleaning’ out the detritus. Now I wish the same could be said for all the e-paper I am receiving, especially those articles and reports dealing with something called the GHS.
Since the beginning of 2012 I have received (and worked my way through) some 3,684 pages of information and “guidance documentation” on the implementation of GHS, which = The Globally Harmonized System of Classification and Labeling of Chemicals.
So far I have learned that we are, once again, mired in legalese and regulatory documents attempting to explain a ‘new’ simpler, easier and universal system of labeling and information transmission for chemicals. I also have decided that I am glad I am not running a chemical manufacturing or shipping company because although the reasoning behind the GHS and the end result will be awesome, the implementation (to be finalized over the next three years) will be an interesting challenge for most chemical manufacturers.
However, the results that we have been seeing are really quite exciting - well for those of us who care about an MSDS/SDS and labeling, that is J
Now the real question is what does it mean to us?
In TWO WORDS OR LESS: Not much
With a minimal amount of work, primarily in our Hazard Communication program training, we will finally be rewarded with Safety Data Sheets (SDSformerly known as MSDS) that are uniform, easy to read and make sense!
Some things to take note of:
A Brief History of GHS: It is not a new idea
How does this affect us?
- It was first discussed in 1983
- It was hoped that a universal harmonized system (GHS) would be in place by 2000
- However it was not until 2005 that OSHA finally agreed to modify the HCS (HazardCommunication Standard) to add the adoption of GHS.
- In 2009 OSHA asked for input from any and all interested parties
- August of 2011 OSHA postponed release of final documents
- Sept of 2011 OSHA issued final recommendations and guidelines for implementation, with a three year window for companies to implement the GHS in their HCS programs
- 2012 begins the three year timeframe to begin implementation of GHS
- 2015 the date by which all chemical companies should have switched over product labeling and labeling on items transported to GHS
1) Terminology: switch from term MSDS to SDS
We need to adjust our terminology when referring to the informational sheets we have come to know and love as MSDS (Material Safety Data Sheets) to simply SDS (Safety Data Sheets).
2) Pictograms: include in our HazComm (Hazardous Communication) training pictograms that our employees may see on the SDS.
There are nine basic pictograms and they are not, for the most part, familiar to us in the veterinary industry.
3) Mention difference between old labels and new, in other words discuss GHS vs. HMIS vs. NFPA labeling
a) Signal words are used in GHS. There are only two:
· Danger: indicates a more serious potential hazard
· Warning: indicates a less serious potential hazard
b) Numbering reflecting severity: GHS numbering system is completely opposite HMIS or NFPA labels
GHS Label NFPA label HMIS Label
The significant difference between the SDS and labeling in the GHS system and the more familiar HMIS or NFPAA labels we currently use, is that the numbering system is completely opposite. For example a 1 in our current labeling system means slight hazard, whereas the 1 in the GHS system means high danger: warning of a serious hazard. Table below shows this more clearly.
Two numerical rating systems are currently used in the United States: NFPAA and HMIS III
Table 4 compares these rating systems to the GHS classification system.
Table: GHS Classifications Compared to NFPA and HMIS III Rating Systems*
* HMIS® is a registered trademark of the National Paint and Coatings Association (NPCA). NFPAA is the National Fire Protection Association
HMIS III Rating
| Flash point < 73°F(23°C) and initial boiling point <100°F(37.8°C)
| 1 or 2
| 4 |
| Flash point < 73°F(23°C) and initial boiling point > 100°F(37.8°C) and Flash point >73°F(23°C) and < 100°F(37.8°C)
| 2 or 3
| 3 |
| Flash point ≥ 100°F(37.8°C) and < 200°F (93.4°C)
| 3 or 4
| 2 |
| Flash point > 200°F(93.4°C) and will burn in air when exposed to a temperature of 1500°F(815.5°C) for a period of 5 min.
| 1 |
Is this going to affect our secondary container labeling?
No. OSHA has decided that employers may choose to continue to use the current HMIS or NFPA type labeling systems for materials in secondary containers. That means the secondary container charts we use will also continue to be acceptable. This is simply because inclusion of GHS does not change the HazComm standard, it simply clarifies primary labeling and SDS development requirements for industry. All compliance regulations in the Hazardous Communication standard still apply.
Bottom-line for us in the veterinary industry:
· Be aware of these changes on the horizon in labeling on packages and in the look of the SDS
· Train: Incorporate the information on these changes into your HazComm training program
Special Note: February reminder- don’t forget to post your 300A form from February 1- April 30! We are NOT exempt if we had more than 10 employees at any time during 2011.
Chery F. Kendrick, DVM, MPVM, MLT, CFS is a writer, educator, speaker and consultant. She is the nation’s leading veterinary regulatory control and OSHA expert. Her time spent in Washington D.C. as an advocate for the veterinary profession with OSHA and other regulatory agencies has resulted in many positive compliance changes for our industry. Her manuals and training programs are used by clinics and animal care facilities nationwide. She speaks nationwide at association meetings and workshops. Please feel free to contact her at DocChery@charter.netwith your questions and visit her web site at www.kendricktechservices.com.