With the deadline to have safety data sheets revised to comply with the updated HazCom Standard brought on by GHS fast approaching here in the United States it is time to face it – authoring compliant SDSs just got a lot more complicated. Better to start the process of updating your SDS documents now rather than wait until the last minute and have poorly written or even worse non-compliant (not updated) SDSs. Although OSHA has not (at this time) published any guidance documents for field auditors regarding updated SDSs it is easy to say that an outdated SDS will stand out like a sore thumb. As you look to update SDSs for your products here are some of the most common mistakes and misconceptions regarding authoring an updated SDS for your consideration:
Not including a date of preparation on your SDS.
This is by far the MOST common mistake on SDSs.
If I change the header on my Material Safety Data Sheet (MSDS) to be Safety Data Sheet (SDS) that will make the document compliant with the new standard.
Not true – you will need to evaluate your entire MSDS for both content AND format as you update it to be an SDS under the new HazCom Standard.
All my SDS needs is a GHS pictogram and it will be compliant.
Just because you include a GHS pictogram on your “revised” SDS does not necessarily make it compliant with agencies that have adopted GHS (specifically EU CLP and OSHA HazCom 2012). The SDS must include classifications, as well as pictograms, signal word, hazard statement and precautionary statements all in the format specified by the agency.
My SDS adequately communicates the hazards – what I have is fine.
With the adoption of the new standard you will no longer be left to “adequately” communicate the hazards of your materials under OSHA’s new HazCom Standard, but instead the format and even some of the text used to communicate hazards is now specified in the new standard.
I can use an older formatted SDS and just add the new classifications, pictograms, Signal word, hazard statement and precautionary statements.
Because you will not be evaluating the entire SDS, choosing this as the method to update your SDSs may inadvertently leave out some of the minimum information that is now required in various sections of an SDS. Not familiar with this requirement – take a look at Appendix D of the revised OSHA HazCom Standard – the required information is far more extensive that it used to be under the old standard.
Just plain not being familiar with the regulations and the new classification cut-offs.
Under the new HazCom standard there are some very specific criteria that determines what classifications are applicable to a material – without this knowledge you run the risk of both over-classifying or under classifying your material.
Take a look at your SDS documents and ask –what will it take and how will I make my MSDSs into compliant SDSs?