How to SDS, Part 2: Essential Best Practices for SDS Authoring

As a chemist or engineer tasked with writing Safety Data Sheets (SDS) for a variety of individual substances and mixtures, there is no greater challenge than basing conclusions of harm (and the risk of harm) on accurate mathematical equations.

Isn't that the exact point of SDS: To essentially protect different categories of personnel and the public who will work with or be exposed to chemicals used in your products?

Below are best practices that you and your team can employ (and train SDS authors on) when starting the process of writing brand new SDS or revising others to comply with new requirements such as the Occupational Safety and Health Administration (OSHA) revision of the Hazard Communication Standard to align with the Globally Harmonized System (GHS).

Understanding Your Chemicals

This seems simple, but ask yourself this: do you have an accurate inventory of each chemical substance and each mixture which will result in a new chemical substance?

In order to succeed in your SDS efforts, you must know what you are working with so that you can write SDS for each chemical component (substance or mixture). This requires information gathering across your business lines and supply chain.

Mastering Mathematical Complexity in SDS

If you are in the business of creating SDS, then you'd better be good at math and equations. The GHS compiles mathematical formulas in what is to referred to as “the Purple Book.” Keep in mind that the point of these mathematical equations is to decipher the hazards involved with each chemical.

This might seem somewhat easy if you have one isolated chemical (e.g., lead, sulfuric acid, ammonia, ethanol). However, when chemicals are mixed together, then you are dealing with ratios (often uneven) and the creation of a whole new substance.

Think about the realities of mixtures with the below example:

• Lead is a substance that is on the periodic table and has a CAS number. The composition of lead is defined. The risks of lead at various levels of exposure can be quantified and reinforced by regulatory limits prescribed. The toxicity of lead is well known.
• However, what if your product mixes lead with another two substances? For our illustration here, we will use substance X and substance Y. This results in Lead + X + Y = Mixture 1. What is Mixture 1? How can you decide how toxic that mixture is?

Now you need a complex formula (perhaps from The Purple Book) to figure out the toxicity of the mixture and the associated hazards. Assuming there is a 1/3 ratio of lead, 1/3 ratio of X, and 1/3 ratio of Y, one option is to calculate the toxicity of each individual component to extrapolate what the overall toxicity would be.

However, this type of mathematical approach is not ideal because it would leave variables unknown (e.g., bioaccumulation might increase the toxicity of the new substance created by the mixture; chemical reactions could, on the other hand, nullify some of the toxicity, and mixtures might result in new substances altogether that are regulated differently under federal and state laws).

Certain regulations like the regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) in the EU require testing protocols to be used to determine toxicity. One can test each individual substance or the mixture as a whole. The good news is that computer systems and software solutions (like ours) can do the math for you – you just need to set up the substances and mixtures properly in the system.

As mentioned before, the key to success and accurate results is to have clear, defined, and specific base information on chemicals.

Adapting to Global Regulatory Requirements

So, you have your substances and mixtures compiled. You mastered the math, and you can now determine toxicity and hazard risks. But that doesn't matter unless you know which SDS template to use.

If you are in the United States, you must identify the agency responsible for overseeing SDS. This agency is OSHA. OSHA provides a sample SDS that can get you started on your journey. As mentioned in How to SDS Part 1, there are required sections and optional ones.

Other countries may have different formats that you need to follow. For instance, Australia provides a document that you would need to read through and assess when putting together your SDS for operations that impact Australia. If you do need to compile SDS for Australia, then you need to pay attention to the section breakdown provided for the document (just as in the US template).

You may have substances that travel internationally throughout your distribution systems. Thus, it is vital that you: 1) identify the relevant countries that your product touches and 2) research and confirm your understanding of the country-specific SDS requirements.

In short, this step requires a regulatory review of SDS specific requirements that is comprehensive enough to encompass all of your relevant jurisdictions. You should also develop a system for horizon scanning for changes that occur in regulatory requirements.

Recognizing the Importance of SDS Compliance

It is always easier to do work when you know the value of it. In essence, SDS are meant to protect your employees and other stakeholders working with hazardous and toxic chemicals.

Section 4 of SDS in the US contains first aid measures. What happens if a spill occurs and one of your employees is exposed to a toxic substance or mixture? It is best to act fast and Section 4 provides very specific advice that will help protect the employee from harm (e.g., if there is eye contact, remove contact lenses). Emergency personnel are also provided with guidance on how to safely address emergencies that require first aid.

Section 5 protects firefighters in particular because those who come to save employees must be able to do so safely or they won't be of much help.

Section 6 covers the measures to take in the event of accidental releases.

Section 7 covers handling and storage, which allows safety directors to determine how to properly use the substances (or mixtures) in their lab.

See: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppD

The list goes on, however, the main point of the SDS is to use the risk of hazards to inform how to handle the substances and, strategically, whether to consider safer alternatives based on your overall risk tolerance.

Leveraging SDS Authoring Software for Simplified Compliance

When preparing SDS, no matter the jurisdiction/country, it is important not to overclassify or under classify hazards. If ever substance is horrible, then nothing is. This is a bit of a mental exercise – think of the “boy who cried wolf” story from your youth. Likewise, if you under classify, then you do a great disservice to those working with or otherwise exposed to the substances, not to mention you risk non-compliance with SDS requirements.

Secondly, keep in mind that toxicological data is open to interpretation. It is wise to have data and reasoning to back up the conclusions that you make when compiling your SDS.

Stay tuned for the third installment of the “How to SDS” blog series where we delve into how technology can help.

To learn more about 3E’s SDS Authoring solutions, please visit this page.