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The transition from material safety data sheets (MSDS) to safety data sheets (SDS) occurred in June 2016. Has your practice or facility successfully transitioned to SDS? It may seem like a large task, but we’ll help break it down for easier understanding of the what, why, when and how of this transition.
What are SDS? The new global standard
SDS (formerly MSDS) are documents that provide users with information on specific dangers of hazardous chemical products and provide guidance on their safe handling, storage and disposal. Chemical manufacturers and medical supply distributors are responsible for evaluating chemical hazards and producing SDS and labels for healthcare providers and others users.
The transition to SDS involves an improved labeling requirement that is aligned with a globalized standard in place for all hazardous chemicals. The new label elements and SDS requirements are designed to improve worker understanding of the hazards associated with the chemicals in their workplace:
- Label on the container
- Product identifier – a code and a product name
- Supplier information – company name, address, emergency phone number
- Precautionary statements – such as keeping the container tightly closed
- Hazardous signal words and pictograms – which help reduce language barriers for workers
- Supplemental information – directions for use, lot number, filled date or expiration date
Why did this transition happen? SDS requirements and benefits
MSDS has long been a primary tool of OSHA’s Hazard Communication Standard (HCS). The HCS was revised by OSHA in 2012 to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). With GHS, hazardous classifications for health and physical hazards must be included on all hazardous chemicals, substances, dilutes, solutions and mixtures. This resulted in substantial changes to the MSDS, including the use of new labeling elements and a standardized format for producers and users. It also resulted in the renaming of material safety data sheets to safety data sheets.
A major advantage of the new SDS requirements is that you’ll now have the information to compare products more easily due to the extensive information that is now required on all labels:
|On every SDS (mandatory):
||On every SDS (non-mandatory):
When did the transition happen? Key SDS dates to know
December 1, 2015: This was the last day for shipments of chemicals under the existing regulations in which manufacturers and distributors could ship a product that falls under these guidelines with the old MSDS label.
June 1, 2016: Final implementation of SDS throughout the U.S. June 1 was the deadline for employers to have SDS available and comply with all training and product labeling requirements. Employers must make a reasonable effort to comply.
How should I prepare for the transition? SDS compliance, training, and storage
As manufacturers and distributors comply with these new regulations and update to the SDS format in the coming months, it is your responsibility to make sure that you are attempting to be compliant.
Steps to prepare for the MSDS to SDS transition:
Step 1: Learn the standard & identify responsible staff
Identify the person(s) responsible in your practice or facility for developing and maintaining an inventory of all hazardous chemicals on premises.
Step 2: Prepare & implement a written hazardous communication program
Make sure you develop or revise your Hazardous Communication Program to include:
- Employee training
- Employee access to SDS
- Having SDS available for all the hazardous chemicals on your premises
Step 3: Ensure containers are labeled with the new SDS
Update your SDS inventory as new products are added as part of the procurement process. If you are purchasing new chemicals, new prescriptions, or other hazardous chemicals, you want to make sure that you have an SDS when that arrives and that it is input in to the system. You should be prepared to update all workplace labeling. Once you receive new SDS for any given hazardous chemical, you must maintain them. Once they are available from distributors and manufacturers, you must use and maintain them – this is what OSHA will measure.
Step 4: Maintain Safety Data Sheets (SDS)
Maintain an electronic library of SDSs for all employees to access. You want to capture data available at critical junctures in the supply chain. If you don’t have an inventory of SDS, you will want to develop one. Good sources include:
- Preferred vendor relationships that maintain this type of information
- Online purchasing systems, exchanges and sites from distributors
- Information management system so that you can organize, manage inventory and reduce costs by implementing these best practices
SDS storage options include either paper systems or electronic systems. It is also important to keep a “simple” back-up (e.g., external drive or single printed binder that is easily accessed in the event of an emergency or power outage).
Step 5: Inform & train employees
Employee training is needed early in the transition process since workers are already beginning to see the new labels and SDSs on the chemicals in their workplace. To ensure employees have the information they need to better protect themselves from chemical hazards in the workplace during the transition period, it is critical that employees understand the new label and SDS formats.1
If you already have a hazardous communication training program, you may simply have to update it to comply with HazCom 2012 (the hazardous communication standard revised in 2012). In particular, you will need to train your employees about the new label and SDS formats they will be seeing in their work areas. Additional hazard training is not required if you have already trained under the existing hazardous communication requirements.