Listen. We won’t name names but we know that there are a few of you – maybe more than ‘a few’ – who haven’t fully made the switch from MSDSs to GHS-compliant SDSs. And even though SDSs are kind of our thing, we get it: The requirement was a big ask of business owners already juggling a lot.
In fact, while U.S. business owners were supposed to comply with OSHA’s June 1, 2015, deadline, the specific conversion requirements were confusing, ambiguous, and easily relegated to the bottom of a to-do list.
Because while the assumption has been that businesses had already satisfied the requirements in the years since the deadline, the reality is that for many, it simply wasn’t a priority, especially since OSHA inspections are rare.
But this isn’t another foreboding, ominous warning to scare you into compliance. We’re sure you know the statistics and that you’ve heard the stories about OSHA fines. We recognize that you’re busy and this may not be a priority for you – but it is our top priority.
We’re here to help so below, we’ll break down an SDS baseline checklist in order to get you compliant.
The Six (6) Label Elements of a GHS SDS
- Address and telephone number
- Product identifier
- Signal word
- Hazard statement(s)
- Precautionary statement(s)
While GHS is a ‘Globally Harmonized System,’ it’s important to recognize that some countries have the option to adopt and implement differently, which creates varied transition deadlines. Generally speaking, however, U.S. GHS-compliant SDSs are valid globally with a few exceptions, such as the EU. Therefore, to conduct business with an EU-based company, you would have to re-author or convert your SDSs accordingly.
Trade Secrets and Proprietary Ingredients
In the U.S., OSHA allows for claims of trade secrets and proprietary ingredients on GHS-compliant SDSs. However, in addition to federal regulations, there are also state-specific requirements that may apply to your products.
And if you elect to use a service provider to facilitate your transition, identify which ingredients are proprietary at the onset of the conversion process in order to ensure protection for those ingredients.
While you aren’t required to disclose the exact percentages of mixture components, you must provide the composition information as a range of percentages, such as ‘5-10 percent.’ Further, OSHA requires that all hazardous components in excess of 1 percent be disclosed, as well as carcinogens in excess of 0.1 percent.
OSHA defines a physical hazard as ‘a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.’
Further, OSHA classifies physical hazards into 15 categories:
- Flammable Gases
- Flammable Aerosols
- Oxidizing Gases
- Gases Under PRessure
- Flammable Liquids
- Flammable Solids
- Self-Reactive Chemicals
- Pyrophoric Chemicals
- Self-Heating Chemicals
- Chemical Which, In Contact With Water, Emit Flammable Gases
- Oxidizing Liquids and Solids
- Organic Peroxides
- Corrosive to Metals
- Combustible Dust
While this baseline checklist only scratches the surface of OSHA GHS compliance, at Global Safety Management, helping our clients be – and stay – compliant is what we do. Everything we do is straightforward and affordable and with our web-based software, your safety data sheets are always readily available, up-to-date and easy to use when and where your people and customers need them – even on mobile devices.
So if you have questions or concerns about GHS compliance or MSDS conversion, or are ready to make the switch once and for all, contact us today.