How to SDS, Part 1: The Basics

Imagine that you are tasked with creating and managing all Safety Data Sheets (SDS) for a product line in your company. This is a daunting task, particularly if you are new to the job. So, let's break down how to get started by discussing what a SDS is, how it should be authored, options for authoring, and keeping SDS up-to-date.

What are Safety Data Sheets (SDS)?

Think of SDS as “cheat sheets” for individual chemicals or mixtures. SDS have all relevant information about how to keep individuals working with these chemicals safe, including information regarding what to do in the event of contact or a release. Requirements for SDS in the United States stem from the Occupational Safety and Health Administration (OSHA)'s Hazard Communication Standard, 1910.1200 App. D.

Key Sections of an SDS

There are 16 sections of information in an SDS. Per OSHA, Sections 1-11 and Section 16 must be filled out. The other sections of information: Sections 12-15, are not mandatory, however, best practice is to fill these sections out so as to be consistent with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). OSHA summarizes what is required by each Section in this helpful brief.

Note that the required sections from Table D.1 include:

1) Identification of the chemical – which chemical are you working with and how so? E.g., what is the chemical normally used for and what restrictions apply, if any?

2) How is the chemical classified via “hazard identification,” including symbols and precautionary statements – this is a visual component.

3) CAS numbers and other ingredient identifiers – with guidance on trade secrets.

4) How to handle first aid in the event of exposure.

5) How to extinguish fires and personal protective equipment (PPE) for fire-fighters.

6) How to handle accidental release such as PPE, emergency procedures, clean-up.

7) Safe handling and storage practices.

8) Exposure limits/Personal Protection (OSHA's permissible exposure limit (PEL) for the chemical, amongst other limits.

9) Physical/Chemical properties (think back to physics and chemistry class – what is the boiling point, what is the flash point, ignition temperature, pH, flammability, etc.).

10) Stability/Reactivity (again, think back to physics class – what is the reactivity of the chemical, stability, static discharge, etc.).

11) Toxicology (exposure routes, symptoms, interactive effects, carcinogenic effects, etc.).

16) Date of preparation/revision.

Note that the recommended (non-mandatory) sections include:

12) Ecological impacts such as ecotoxicity, bioaccumulation, etc.

13) Disposal such as the safe handling of waste

14) Transportation information such as the United Nations (UN) number, shipping name, etc.

15) Applicable regulations.

Note: These sections do not need to be kept in a particular order. However, the mandatory sections must be included nonetheless.

For example SDS, see: https://www.osha.gov/sites/default/files/2020-04/Sample%20SDS%20Handout.pdf

Who Needs to Maintain SDS?

According to OSHA, you must create SDS if you are a chemical manufacturer or an importer. In addition, other responsible parties (e.g., suppliers) must keep SDS. There are many benefits for all parties to streamlining the process from beginning to end.

Benefits of Streamlining SDS

Streamlining, in this context, does not mean short cuts. In this context, streamlining is the development of a strategy for authoring SDS and keeping them compliant that reduces risk for companies. For example, SDS should be kept in one place, organized by chemical, easily accessible, and ready for revision when necessary.

This requires up-front organization and a workflow process that is iterative. For example, steps could be: 1) Author SDS, 2) Review SDS periodically to make sure that they are still relevant to product lines, 3) Add new SDS for new chemicals, and 4) Update SDS on a pre-determined frequency (by accessing regulatory developments and news)

Streamlining can be beneficial for all parties:

• Manufacturers overseeing the overall product production need to develop a process for SDS creation and update with the strategic aim of protecting employees and providing immediate access to SDS for employees.
• Importers need to access relevant SDS so as to comply with domestic and international regulations
• Suppliers who make product components must be aware of the chemicals used to make these components to meet health and safety goals – which comes from accessing SDS.

In turn, streamlining depends upon accurate authoring of SDS.

Best Practices for SDS Authoring

Stay tuned for our second installment of this three-part blog series: Best Practices for Authoring SDS.

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