SDS Authoring Risk Alert: OSHA Requires Checking Full Range of Data Sources for Hazards

OSHA regulations call for firms to “identify and consider the full range of available scientific literature and other evidence concerning the potential hazards” when authoring an SDS (§1910.1200 (d) (2)).

SDS Authoring Risk

Unfortunately, many organizations expose themselves to significant risk by only checking one or two common sources. When they cannot find an endpoint from one of these select and convenient sources, they just assume one is not available. In doing, they are out of compliance and opening their organization up to potential criminal and legal liability.

Take this real example of SDS authoring risk:

You need to identify critical endpoints such as primary irritation; mutagenic effects; reproductive effects; tumorigenic effects; and multi-dose (target organ) effects as part of creating an SDS for one of your products. You immediately check LOLI, which is an outstanding go-to source for data. However, while LOLI has acute toxicity data, it is lacking the data for the endpoints you seek.

In the above example, many organizations would simply indicate that the endpoints were not available and assume no hazards are present.

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The right approach is to check additional sources, including the NIOSH Registry of Toxic Effects of Chemical Substances (RTECS®) database, along with other supporting data sources such as Toxnet and the NIOSH pocket guide. These sources provide necessary data for these endpoints to assist in the hazard determination/classification process.

If you engage a professional services firm to author Safety Data Sheets on your behalf, understand that third-party authoring organizations include terms in their contracts that disavow and/or limit liability. So, choose a partner that takes a thorough approach. As the product manufacturer, you bear the risk.

When it comes to authoring, ignorance is not bliss!

To learn more about how to maximize compliance, reduce risk, and yet still rapidly obtain a cost-effective and tailored SDS, contact SiteHawk today.

About Ruth Donlon

Ruth Donlon leads SiteHawk’s authoring and regulatory services group. A SiteHawk and authoring veteran, Ruth holds a B.S. in Environmental Science from Lipscomb University. In her 15 years in the industry, Ruth has helped everyone from industrial manufacturers and natural resources entities to package food companies and chemical conglomerates create a safer & healthier workplace and produce safer products. At home, Ruth enjoys cooking, crafting and spending family time with her husband and two children and as a true Nashville (and music) lover, is a perennial attendee of Bonnaroo.