Listen. We won’t name names but we know that there are a few of you – maybe more than ‘a few’ – who haven’t fully made the switch from MSDSs to GHS-compliant SDSs. And even though SDSs are kind of our thing, we get it: The requirement was a big ask of business owners already juggling a lot.
In fact, while U.S. manufacturers and distributors were supposed to comply with either OSHA’s June 2015 or December 2015, deadline, the specific conversion requirements were confusing, ambiguous, and easily relegated to the bottom of a to-do list.
While the assumption has been that businesses already satisfied the requirements in the years since the deadline, the reality is that for many, it is not clear they have actually met the GHS requirements. Many have taken a “good enough” approach simply because either they didn’t understand the requirements or they haven’t had the resources to ensure their SDS are compliant. This has led to an abundance of non-compliant SDS or misclassified hazards.
We’re here to help so below, we’ll break down an SDS baseline checklist in order to get you compliant.
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The Six (6) Label Elements of a GHS SDS
- Name
- Address and telephone number
- Product identifier
- Signal word
- Hazard statement(s)
- Precautionary statement(s)
- Pictogram(s)
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Global Compliance
While GHS was meant to be a ‘Globally Harmonized System,’ it’s important to recognize that many countries opted to adopt and implement it differently. This is why most now say that GHS is not global and not harmonized. For those who sell to customers outside the United States, this has only added to the confusion and complexity, because, for example, o conduct business with an EU-based company, you would have to re-author or convert and translate, your SDSs accordingly.
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Trade Secrets and Proprietary Ingredients
In the U.S., OSHA allows for claims of trade secrets and proprietary ingredients on GHS-compliant SDSs. However, in addition to federal regulations, there are also state-specific requirements that may apply to your products and the disclosure of hazardous ingredients.
And if you elect to use a service provider to facilitate your transition, identify which ingredients are proprietary at the onset of the conversion process in order to ensure protection for those ingredients, while also complying with the disclosure requirement.
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Mixtures
While you aren’t required to disclose the exact percentages of mixture components in the US, you must provide the composition information as a range of percentages, such as ‘5-10 percent.’ Further, OSHA requires that all hazardous components in excess of 1 percent be disclosed, as well as carcinogens in excess of 0.1 percent.
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GHS & OSHA Hazards
The Globally Harmonized System, or GHS, separated hazards into one of three types: physical, health or environmental. OSHA did not adopt GHS Environmental hazards into its standard and only incorporated physical and health hazards into HazCom 2012.
OSHA defines a physical hazard as ‘a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.’
Further, OSHA classifies physical hazards into 15 categories:
- Explosives
- Flammable Gases
- Flammable Aerosols
- Oxidizing Gases
- Gases Under Pressure
- Flammable Liquids
- Flammable Solids
- Self-Reactive Chemicals
- Pyrophoric Chemicals
- Self-Heating Chemicals
- Chemical Which, In Contact With Water, Emit Flammable Gases
- Oxidizing Liquids and Solids
- Organic Peroxides
- Corrosive to Metals
- Combustible Dust
According to OSHA, Health Hazards “can harm human health through a variety of routes.” They can cause acute or chronic symptoms that affect the eyes, skin, reproductivity and specific target organs. They can also be toxic, corrosive, or carcinogenic. These health hazards fall into 11 general, non-exclusive classifications:
- Acute Toxicity
- Skin Corrosion/Irritation
- Serious Eye Damage/Eye Irritation
- Respiratory or Skin Sensitization
- Germ Cell Mutagenicity
- Carcinogenicity
- Reproductive Toxicity
- Specific Target Organ Toxicity – Single Exposure
- Specific Target Organ Toxicity – Repeated or Prolonged Exposure
- Aspiration Hazard
- Simple Asphyxiants
While this baseline checklist only scratches the surface of OSHA GHS compliance, at Global Safety Management, helping our clients be – and stay – compliant is what we do. Everything we do is straightforward and affordable and with our cloud-based software, your safety data sheets are always readily available, up-to-date and easy to use when and where your people and customers need them – even on mobile devices.
So if you have questions or concerns about GHS compliance or MSDS conversion, or are ready to make the switch once and for all, contact us today.
