Have you replaced your MSDS with SDS?

What is MSDS vs. SDS and have you replaced yours?

Employers, as well as chemical manufacturers, distributors and importers, replace have replaced their Material Safety Data Sheets (MSDS) with new Safety Data Sheets (SDS) by June 1, 2015.

In 2012, Fed/OSHA and state OSH programs modified hazard communication (HazCom) standards to conform to the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Fed/OSHA’s final rule became effective on May 25, 2012. See 29 CFR 1910.1200.  Fed/OSHA applies in 26 states. The remaining states have their own occupational safety and health (OSH) programs, and while most typically adopt Fed/OSHA standards, some adopt their own. As an example, in California, Cal/OSHA has its own version of a GHS-compliant HazCom 2012 standard—8 CCR § 5194. The updated HazCom standards are often referred to as HazCom 2012. There are a number of exceptions in the standards and some variations under some of the state OSH programs, but the basic requirements are standard and discussed below.

Under HazCom 2012, by June 1, 2015, chemical manufacturers, distributors, and importers must provide a GHS Data Safety Sheet in the new format for each hazardous chemical they manufacture, distribute, or import, and employers must ensure that SDSs, in this new format, are readily accessible to employees who handle or are potentially exposed to a hazardous chemical. 

What does MSDS stand for?  

MSDS was formerly called the Material Safety Data Sheet.

What does an SDS stand for and what information does and SDS contain?

An SDS stands for “Safey Data Sheet” which was formally a MSDS. This contains environmental, health, and safety (EHS) information for a specific chemical product, including the physical and chemical properties of that product, the potential hazards of that product, precautions to take by employees using the product to prevent harmful exposure, and emergency procedures in case one is exposed to the product or it is accidentally released to the environment. There are national and international guidelines to be followed, and some states require additional information to be included, like Prop 65 here in California.

What were the compliance deadlines?

HazCom 2012 established a number of compliance deadlines.

• December 1, 2013: Employers have trained employees on the format and presentation of the HazCom 2012 labels and SDS.
• June 1, 2015: Compliance met for the new HazCom provisions, with one exception. Distributors had until December 1, 2015 to ship products with the new GHS labels
• June 1, 2016: Employers update alternative workplace labels and HazCom programs and provide training on newly identified hazards.

What is the difference between MSDS and SDS?

As a practical matter, the most significant major change required by June 1, 2015, was the switch from MSDS to SDS. The information contained in SDS is similar but not identical to that in an MSDS, and the SDS must be presented in a new “user-friendly,” 16-section format. with the following section numbers and headings:

1. Identification
2. Hazard(s) Identification
3. Composition/Information on Ingredients
4. First-Aid Measures
5. Fire-Fighting Measures
6. Accidental Release Measures
7. Handling and Storage
8. Exposure Controls/Personal Protection
9. Physical and Chemical Properties
10. Stability and Reactivity
11. Toxicological Information
12. Ecological Information (non-mandatory)
13. Disposal Considerations (non-mandatory)
14. Transport Information (non-mandatory)
15. Regulatory Information (non-mandatory)
16. Other Information

For details about the specifications for each of these 16 sections, please see Appendix D of 29 CFR § 1910.1200.

Please note that Fed/OSHA has stated that it will not enforce the SDS requirements related to Sections 12 through 15 since other agencies already enforce these requirements, see 29 CFR 1910.1200(g)(2). Thus, these sections are considered non-mandatory by Fed/OSHA.