In the United States, there are various regulations affecting how MSDSs are used to evaluate and eliminate risk. The impact MSDSs have in global safety programs continues to evolve, and changes are underway that will shape the way companies effectively communicate potential hazards across international boundaries.
Evaluation phaseEffectively integrating MSDSs into a functional health and safety program requires a hazard exposure evaluation. Chemical information provided on the MSDS is used to develop written personal protective equipment (PPE) programs, work rules, training curricula and other aspects of a safety program. Safety programs fall short of their intended purpose, however, when resources such as MSDSs are not fully optimized beyond the hazard identification phase.
Hazard mitigation is preceded by hazard recognition, hazard identification and hazard evaluation. The evaluation phase consists of analyzing MSDSs and determining what chemical exposure risks exist for specific job tasks or how the environmental factors of the area in which tasks are being performed will impact the stability and safety of a specific chemical.
A job hazard analysis (JHA) is a technique that allows the safety professional to evaluate exposures and risks related to a chemical hazard. The objective of a JHA might be defined by two fundamental but critical questions related to chemical hazards:
- How could the user of this chemical be exposed to the hazards?
- What measures must be taken to protect the user from known hazards?
When prepared and implemented effectively, a JHA standardizes work practices to mitigate the human factors that increase risk of exposure. Job hazard analysis involves breaking down a task into its individual steps and identifying the hazards related to each step. From the hazard identification, the appropriate protective measures, such as engineering controls, administrative controls and/or PPE, can be defined.
The producerâ€™s roleHazard mitigation begins with MSDSs, which are an important component of a multi-pronged hazard communication process. There are compliance requirements related to an MSDS throughout the life-cycle of a chemical, from its generation or import by the manufacturer to its handling and use by the consumer.
The Occupational Safety and Health Administration (OSHA) Hazard Communication standard in 29 CFR 1910.1200 requires chemical manufacturers, importers, distributors and employers to provide hazard information to customers and affected personnel. Hazard analysis is a critical tool necessary for both the manufacturer to initially create the MSDS and the end-user to effectively assess the risks associated with the chemical.
Beginning with the production process, chemical manufacturers and importers are responsible for identifying health and environmental hazards associated with a chemical and communicating such hazards to product users. These entities are not required to adhere to any specific methodology for determining a chemicalâ€™s hazard. Rather, they must be able to demonstrate that the hazards have been adequately evaluated with regard to carcinogenicity, human health data, animal test data and other scientific studies. Hazard determination relies significantly on the expertise and judgment of the evaluator.
The American National Standards Institute (ANSI) has developed an MSDS standard, ANSI Z-400.1 2004, which provides guidance to chemical manufacturers regarding the hazard determination process.
The employerâ€™s roleOnce the product is introduced into commerce in a workplace setting, the responsibility falls on the employer to communicate the information provided by the manufacturer to its employees and other affected personnel.
The safety hazard of a chemical, as determined by the manufacturer, is a constant, regardless of how it is used or handled. In other words, its health hazard, ignitability, reactivity and other special conditions will not change assuming that its chemical and physical properties remain unaltered. The risk associated with a chemical, however, will change depending on how the chemical is used, handled or disposed.
From an end-userâ€™s perspective, the Hazard Communication Standard (HCS) requires an employer to inform workers of the hazards of chemicals in the workplace. The MSDS is one of several means available to convey chemical hazard information. Other OSHA regulations that require an employer to evaluate and mitigate hazards include, but are not limited to, the personal protective equipment standard, confined space standard and the General Duty Clause.
SIDEBAR: GHS: Greater consistency?The future of MSDS use for hazard prevention internationally is just beginning to evolve. The United Nationsâ€™ Globally Harmonized System (GHS) represents one effort to provide greater consistency in MSDS content and labeling to address global commerce issues.
GHS will enhance the protection of human health and the environment by providing a comprehensible system for hazard communication that transcends international boundaries. When fully adopted by participating nations, GHS will minimize inconsistencies in hazard identification across geographic boundaries.