In late 1996, the group issued a 90-page report. OSHA endorsed the findings, but put off taking any action until a global agreement on harmonizing hazard communication requirements can hopefully be reached. So the MSDS headache continues to plague companies large and small.
It's a problem of major proportions. Almost every chemical coming in to a plant has a data sheet attached, whether one is really needed or not. "Just because it comes in the mail doesn't mean it has to be included," says Henry Lick, acting chair of NACOSH and director of industrial hygiene for Ford Motor Co.
MSDSs could be very useful, considering that more than 11 percent of all 1996 workplace deaths resulted from some sort of chemical overexposure, according to the Bureau of Labor Statistics.
But too often MSDSs just complicate hazard communication programs, according to 40 safety and health practitioners contacted for this story. Some skimp over important details. For example, an industrial hygienist from Alabama laments not having more data, such as exposure threshold limits, for deadly chemicals in her workplace.
Then there are MSDSs that create a paperwork nightmare. "It's a real pain when you have to copy five sets of 15-page MSDSs," says Edwin Hatfield, a human resources manager in Missouri. "You can say a lot of this stuff in a lot less words."
Persistent painWhy is it so hard to find relief for the pain caused by MSDSs? There are a number of reasons, according to industry experts. Limiting data sheets to two pages, for example, just doesn't allow for the need for liability protection. And in some cases safety and health risks need more explanation.
The American National Standard for Hazardous Chemicals-Material Safety Data Sheets-Preparation (ANSI Z400.1) was issued in 1993 to address problems through standardizing a MSDS format. The document outlines a model 16-section data sheet (see sidebar). But not all chemical manufacturers will comply with the voluntary standard--again, due to liability concerns. For example, ANSI Z400.1 requires that PPE be recommended for each route of exposure, a responsibility that some manufacturers are reluctant to assume. Plus, OSHA has not endorsed the order and section titles of the ANSI standard, preferring to wait for an internationally standardized format.
The NACOSH report states: "To achieve the greatest possible benefits in terms of improved protection and decreased compliance burdens, global harmonization is the preferable approach." Another barrier to standardization is the broad array of chemical uses and mixtures in the workplace.
What to doIf the MSDS you have for a particular substance doesn't answer your questions about PPE, emergency response, handling and storage, or some other issue, you have to take matters into your own hands, say experts. Use OSHA's PPE standard and accompanying non-mandatory guidelines to identify and analyze chemical hazards, and to select appropriate protective gear, for example.
You might be able to find more complete or detailed MSDSs online. OSHA's web site (www.osha.gov) is a starting point for hunting down a number of resources. Check with your insurance carrier to see if there is an industrial hygienist on staff to answer questions.
You also might want to consider limiting the number of chemical vendors your company uses. This can simplify your data collection and recordkeeping efforts. If you're a large enough end user, you might be able to persuade chemical suppliers to conform to the ANSI standard if they are not already doing so.
MSDS libraries can also be simplified by using commercially available software programs, or by organizing data sheet binders. The tools you use depend largely on the volume of chemicals in your workplace.