Responding to criticisms about the quality of many material safety data sheets (MSDS) circulating in workplaces, OSHA is preparing three guidance documents to improve the quality of chemical hazard information provided to workers.

“Guidance for Hazard Determination” — This guideline will detail and hopefully simplify the process of how to determine a hazard. Per OSHA’s hazard communication standard, chemical manufacturers and importers must evaluate scientific evidence in order to identify hazards associated with any chemical they manufacture or import. This provides the basis for the hazard information provided in MSDSs, on labels and during worker training.

“Guidance for Preparation of MSDSs” — Another of the three guidance documents intended to enhance chemical hazcom, this will help MSDS preparers write data sheets that are clear, consistent and comprehensive. The document includes a recommended MSDS format, instructions for composing individual sections of the MSDS, sources for obtaining information to complete sections, and guidance on what type of information to include in each section. OSHA says this document should help improve both the accuracy and comprehensibility of MSDSs.

“Model Training Program for Hazard Communication” — Employers are required to provide training to employees exposed to hazardous chemicals, and this new guidance document will help develop a training program tailored to the needs of each workplace, regardless of size or complexity. It will help employers explain the information presented on labels and MSDSs.

Look for these documents to made public in 2004.

Under review

In addition to developing the three guidance documents, OSHA has examined some key hazcom issues that the agency says need improvement. OSHA is expected to issue a report on its findings sometime early this year. The issues include:

Complexity of MSDSs: OSHA’s hazcom standard requires MSDSs to be accurate and complete. Since the qualifications of chemical manufacturers and employers writing the MSDSs vary, the quality of the MSDSs also varies. In addition, the availability of information on different chemicals varies widely. Dealing with mixtures of chemicals presents certain challenges as well, and the science regarding certain types of hazards along with various protective measures continues to evolve. All of these factors contribute to the complexity of developing an accurate and complete MSDS, and OSHA is considering how these factors can be harmonized to better facilitate MSDS development.

Multiple elements of hazcom: MSDSs are paramount to a comprehensive hazard communication program. Still, OSHA recognizes that they are only one component of such a program. MSDSs provide detailed technical information and serve as a reference source for workers, but don’t forget that labels and training are complementary parts of a complete hazcom program. Labels are intended to provide a brief, conspicuous summary of hazard information at the site where the chemical is used. Training ensures that workers understand chemical hazards in their workplace and are aware of protective measures to follow.

Each element — MSDS, labels and training — has its place in effectively protecting workers, according to OSHA.

SIDEBAR: Hazcom going global?

OSHA is taking a look at the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) as a way of improving chemical hazard communication. The GHS, according to OSHA, has the potential to serve as a mechanism for addressing many of the concerns that have been raised regarding the comprehensibility of chemical hazard information.

The result of a ten-year effort to establish international consensus on criteria for classifying chemicals according to their hazards, and to create consistent requirements for labels and safety data sheets, the GHS was formally adopted by the United Nations in December 2002, though it has not been implemented in the U.S.

The GHS is intended to:

• Improve the quality and consistency of chemical hazard information;
• Facilitate international chemical trade;
• Reduce the need for chemical testing and evaluation; and
• Provide a recognized framework for those countries without an existing hazard communication system.

In addition to criteria for classifying chemicals according to their health, environmental and physical hazards, the GHS includes standardized requirements for labels and safety data sheets. A standardized 16-section format for safety data sheets provides a consistent sequence for presentation of information. Section headings (e.g., First Aid Measures, Handling & Storage) are standardized to facilitate locating information of interest. The GHS also establishes standardized and more detailed requirements for labels, including consistent use of pictograms, signal words and hazard warning statements.

A document summarizing and explaining the GHS is under development by OSHA to assist in considering adoption of the GHS in the U.S.