Material Safety Data Sheets
The key to safety
By Chris Northedge — Materials Systems Europe, FMC
March 2001
Accidents are bad news, usually costly and rarely good P.R. Our workforce is skilled and valuable; a resource not to be risked, yet workers must use materials that may inevitably be hazardous. The key to doing this safely is the Material Safety Data Sheet (MSDS). It would be nice if we never needed materials that posed a risk but we do, and even "safe" materials may present hazards in some circumstances. For example, water is fine to drink or to bathe in but under high pressure, it becomes very dangerous.
Industrial substances are the issue
But, we rarely use pure substances such as H2O. Most often, we use industrial substances that have many constituents and to handle these successfully, we really need the MSDS. When accidents occur, hospitals will know how to deal with pure substances and medical drugs but they cannot be expected to know the constituents of industrial chemicals. A good practice when taking a worker to hospital is to send the MSDS with him, pinned to his shirt if necessary, to ensure the medical staff get the full picture.
What materials require an MSDS?
Typically, it is the non-dimensional materials which cause hazards — the fluids, gases, and powders. They are not
normally required for components or finished articles but understanding how and when the material is used is important. Brake pads, when new as components, pose negligible risks, but the dust from used pads may include asbestos or other carcinogenic products. Refinishing yellow or red-painted surfaces may produce dust containing hexavalent chromium, which was never a risk when originally painted. Substances commonly available to the public or a drugstore will not normally require an MSDS. Those products will either pose no risk or already be labeled with instructions and the medical profession will know how to handle them.
Legal requirements
The MSDS is required to be used by the Occupational Safety and Health Administration (OSHA) under Federal regulation 29 CFR 1910.1200 and by national legislation in all developed and most other countries.The format is laid down by international standard ISO 11014-1 in 16 sections. Some suppliers/organizations may produce their own versions that alter the order and wording, but the content will be the same.
MSDS information
The content of most sections is obvious
by the titling and these may vary in order of appearance.
Page header – Includes Product name
— exactly as on the label; Internal reference No.; Review date.
Section I – Lists Product and Company
Identification: Product name; Supplier and emergency telephone.
Section II – Shows Composition of and
Information on Ingredients: Names of chemicals; CAS numbers; percent concentration; Hazard Classification. Not all composition may be disclosed as manufacturers may decline to publish any ingredient which give competitive advantage. However, the risks and hazards on the MSDS will have been written in full knowledge of the entire composition.
Section III – Hazards Identification: Most important hazards; Specific hazards; or ’none’.
Section IV – Fire Fighting Measures: Extinguishing media to use.
Section V – First Aid Measures.
Section VI – Accidental Release Measures: Personal precautions; Environmental precautions; Methods for cleaning up. This covers spills and leaks affecting the environment, including release to atmosphere.
Section VII – Handling and Storage: Precautions for safe handling; Technical measures; Storage conditions; Incompatible products; Packaging materials.
Section VIII – Exposure Controls / Personal Protection: Personal protective equipment to be used; Maximum time exposure per eight-hour shift; Short Term Exposure Limit (STEL).
Section IX – Physical/Chemical properties. Physical state, form, odor, color, pH value; temperatures at which physical state changes occur; flash point; auto-ignition temperature.
What does it look like, smell like? This is invaluable for recognition of unknown substances so note carefully.
Section X – Stability and Reactivity: Stability; Hazardous reactions; Hazardous decomposition products.
This section is very important where accidental mixtures take place. Once where a chemical was poured into a drum that was not empty, hydrogen was produced in volume. If the area had not been well-ventilated, the mixture could have exploded with one spark.
Section XI – Toxicological Information: Acute toxicity; Local effects.
Section XII – Ecological Information.
Section XIII – Disposal Considerations: Waste from residues; Contaminated packaging; Regular arrangements for disposal of waste.
Section XIV – Transport Information: IATA – Dangerous Goods Regulations and ICAO-Technical Instructions for international and domestic air transportation requirements will be key, but where several modes of transport are involved, the regulations to consider are:
• Road – US DOT 49 (CFR 172.101), Canadian TDGR Schedule II, SCT- NOM-002-SCT/1994 (Mexico), ADR(Europe)
• Railroad – US DOT 49 CFR; TDGR (Canada); RID (Europe) and sea/ water – IMDG Code amendment 29-98.
Section XV – Regulatory Information: Labeling; Percentages contained.
Section XVI – Other Information: Preparation Information.
The office that prepared the sheet should be stated together with contact telephone numbers (international format) in case of emergency. Most commonly, the manufacturer will have supplied the chemistry and original information. Local reviews and Worker Instruction Sheets may be referred to here.
How the substance is used, applied and stored are important considerations for the MSDS, as are accidental situations where these can be predicted. Volumes also matter — large volumes generally pose higher risks, whereas small quantities pose less. If you think your use is not covered by the MSDS you must contact the manufacturer to get advice.
Where do we keep them?
Easy, rapid access by all the affected workforce, Union representatives included, is essential. The location needs to be close to the workplace. It must be well known, widely publicized, and never locked away. Printed copies are easy to read and need protective covering such as laminating but there is a more fundamental problem — currency of documents. To keep information up-to-date, printed neatly and keep costs down, computers are needed. These days, the MSDS should be kept on the Web, often prefixed as an ’e’-solution.
Search tools are required to retrieve the sheets by product name, supplier, manufacturer, CAS number, review status, material specification, etc. Text-searching tools on the Web lend themselves to keyword searching if this has been set up, or the superior technique of two-word proximity searching may be available. In this case, you might search for ’hydrogen’ and ’ignition’ and the software lists only where the two words are close together. If they were pages apart they would be of no use.
Staying up-to-date
Old information on an MSDS is useless, so
it is critical that only the most up-to-date sheets are used but, you never know when an MSDS is updated. They must be updated at regular intervals (3-10 years) and substances may be withdrawn following international agreements (e.g. CFC’s), so keeping paper copies is inherently risky as the information may easily become out-of-date. For this reason, you should only regard printed copies as ’uncontrolled’ or transient. You really need to check the latest revision date on the Web before use.
Local Reviews
These can be invaluable. The manufacturer or Toxicology/ Hygiene office writing the original review has to cover all hazards and circumstances that could occur, but cannot know the local circumstances of use. A local reviewer will know the safety equipment available to cope with hazards, so comments appended to the MSDS and read in conjunction will almost always make use of the substance safer and more acceptable.
Will the workforce read them?
Getting the workforce to read and understand the information can be quite a problem. It is easy to be complacent or
grudge the time, but you can never be safe unless you know what you are about. The MSDS has to explain its content using text and contains very little visual information, some of which is at ’professional-level.’ It is not bedtime reading.
Worker Instruction Sheets
One solution to address this is to produce one-page summaries with high visual content written in less complex language. The risk/ hazard symbols and pictograms for storage and environmental requirements, etc., can be included. These are generically termed Worker Instruction Sheets (WIS).
WIS have long been legally required in some European countries. Since 1986, in Germany, a "Works Instruction for Employees" must be provided and read at least once per year, and the foreman must positively accept all hazardous materials and sign for them. In Belgium, the Product Safety Card is used, but with less controls,
and now European Union directive 98/24/EG dated April 1998 is interpreted as requiring all EU countries to provide WIS by May 2001.
Language
English is the international language of
aviation, as in many industries, so do we need other languages? Where MSDS are used outside the US, a local language in addition to English may need to be considered, and possibly also for ethnic populations within the US. The problem is one of understanding — We are dealing with critical safety information and so can we really risk accidents from poor understanding simply by ignoring the workers natural language? One practical solution is for double-sided sheets, English one side, local language the other.
The Material Safety Data Sheet is a comprehensive listing of constituents, risks and instructions for using industrial chemicals and substances. Provision of the MSDS is required by law but our obligation extends beyond that to encouraging use. It should be accessed online wherever possible and kept protected near to the workforce and updated regularly if kept in paper format. Ease of access guards against complacency as well as the criticality of every second in an emergency. Through MSDS, the key to safety in the workplace is at hand.
