New approaches in MSDS management
From its inception to present day, the Material Safety Data Sheet (MSDS) has evolved, mostly for convenience, into a document that provides data in greater detail than the standard requires.
The creation and maintenance of Material Safety Data Sheets (MSDS) was mandated by OSHA via the Hazard Communication Standard (HCS) on Nov. 23, 1983, and amended on Sept. 23, 1987, to include all employers with employees exposed to hazardous chemicals in their workplaces. The HCS requires the evaluation of chemical hazards and provides product and/or substance level hazard information to employers and employees.
Some MSDS also offer a significantly broader spectrum of safety information and regulatory data than required by OSHA regulations. The document, in some instances, extends beyond hazardous chemicals to the broader category of regulated materials. As a result, many MSDSs serve as a data clearinghouse for a range of safety and regulatory compliance data to include chemical classification, transportation, environmental, ecological and disposal considerations.
In addition to adhering to international, federal, state and local regulations, compliance today includes two progressive approaches that are being broadly accepted and implemented: corporate social responsibility (CSR) and industry best practices.
CSR has become a business imperative and is a form of self-regulation incorporated into the corporate business model. By implementating a CSR program, a company assumes responsibility for the impact of all corporate activities upon its employees, customers, community and the environment. This often is carried out in the context of voluntary improvement commitments and performance reporting. A wide range of blue chip companies have a stated public commitment to CSR and regularly report (publicly available) on CSR performance.
Emphasis on social environmental and economic sustainability has become a focus of many CSR efforts. The World Commission on Environment and Development, convened by the United Nations (UN) in 1983, redefined sustainability. Companies now are challenged by customers, employees, investors and activists to develop a blueprint for how their organization will sustain economic prosperity while taking care of their employees and the environment.
Industry best practices are designed to leverage integrated compliance management solutions that — through experience, comparative research, analysis, and process assessment — have been proven to reliably lead to a desired result. That result generally leads to one or more of the following improvements: consistency of practice, process control, cost control, record management and content management.
A commitment to deploying best practices is a commitment to using all the knowledge, technology and expertise at one's disposal to ensure safety and compliance. As the regulatory landscape evolves, best practices must be aligned with new and pending requirements to maintain compliance in a rapidly changing environment.
One widely applicable example would be how the role and content of the MSDS has evolved. More changes are in store, as OSHA has released its proposed rule to modify the current HCS to conform to the UN Globally Harmonized System for Classification and Labeling of Chemicals (GHS). The proposed GHS-specific revisions include both philosophical and tactical changes to hazard communications, which have far-reaching implications for MSDS authoring, publishing, distribution and management of labels. Downstream users of hazardous materials will face a significant employee training/re-training requirement, as new classification terminology, risk and safety determinations, hazard symbols and product labels will be subject to change. Increasing the difficulty will be an estimated 3-year transition period in which either the older MSDS versions (non-GHS compliant) and newer GHS compliant versions will be acceptable for use.
The proposed OSHA GHS rule calls for an updated and expanded version of the MSDS, with new information on:
- Firefighting measures
- Accidental release measures
- Handling and storage
- Exposure controls/personal protection
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information.