A little more than one year ago, an entirely preventable tragedy occurred when a UCLA research assistant was burned over 43 percent of her body and died 18 days later in a hospital burn unit. While using a plastic syringe to extract a small amount of t-butyl lithium, a chemical compound that ignites instantly when exposed to air, she was engulfed in a flash fire when the syringe came apart in her hands.1 The accident was attributed to poor technique, improper method, poor training and a lack of supervision. A quick reading of the compounds MSDS might have prevented this terrible loss.
A good system for chemical management begins with a complete inventory of the laboratorys chemicals and an MSDS collection for those materials. This column explains what an MSDS is, what information it contains and how to best use that information.
MSDS is an acronym for material safety data sheet. The purpose of the MSDS is to inform chemical users of the potential hazards encountered with a chemicals use. Both the Occupational Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA) have published regulations dealing with MSDSs. However, most chemical products packaged for consumers and general household uses are exempt from these requirements. We will focus on the OSHA regulation as it applies to all employers and their workplaces. We will begin first with a little history.
MSDS history and regulations
In the 1940s, the Chemical Manufacturers Association (CMA) began producing chemical safety data sheets (CSDSs) for many chemicals used in commerce. These were very detailed in their coverage, the longest of which was some 46 pages. CSDSs are no longer produced or supported by the CMA.
In 1985, the OSHA Hazard Communication Standard (29 CFR1910.1200)2 became effective, requiring manufacturers and distributors to provide MSDSs to their customers. In 1987, this was expanded to all employers with employees exposed to hazardous chemicals in their workplaces. The OSHA definition of a hazardous chemical is broadany chemical which is a physical hazard or a health hazard. We do not know many chemicals that would fall outside that definition. Do you?
Although the hazard communication standard (HCS) does not require a particular format for the MSDS, it does specify what information must be included. Since the HCS does not specify a format for MSDSs, wide variation existed in the order and completeness of the required information by the many different manufacturers and distributors. Recognizing this problem, the CMA worked on developing a voluntary guidance document in an effort to improve the completeness, accuracy and consistency of MSDSs. In 1993, the American National Standard Institute published the first standard for preparing material safety data sheets on hazardous industrial chemicals (ANSI Z400.1-1993)3, an MSDS format containing 16 sections. The current standard is now Z400.1/Z129.1-2010.
The ANSI Z400.1 format for MSDSs incorporates all the information required under the OSHA Hazard Communication Standard (plus a few extras). The ANSI format lists sections in a logical sequence and has gained acceptance by most manufacturers and distributors. Thus, our discussion and comments on MSDS content will follow the ANSI design.
Section 1: Chemical Product and Company Identification
The contents of this section are obvious: the chemical and/or product is named here along with the manufacturer or distributor, and should include the company mailing address and telephone number. A key to this section is that it should relate the MSDS to the container label and shipping documents. Other useful information that is usually included is a brief description of the chemical or product and its general use. Most companies will also give the date the MSDS was written or the date it was last revised.
Section 2: Composition, Information on Ingredients
This important section identifies the hazardous components and amounts of each for the product. This is where you look to see what you are dealing with. The chemical abstract service (CAS) number should be given as this number provides positive identification of each component. The CAS number is important with the many different naming conventions and pseudonyms in use. This section also provides information on published exposure limits, if applicable, such as OSHA permissible exposure limits (PEL), American Conference of Governmental Industrial Hygienists (ACGIH) threshold limit values (TLV), and others like IDLH (immediately dangerous to life and health) limits. If any of the components or their amounts are trade secrets, it must be stated here.
Section 3: Hazards Identification
The materials appearance, odor, health, and physical and environmental hazards are listed in this section. The information here expands on the previous section, providing details on each components hazards, routes of exposure, symptoms for both acute and chronic exposures, and target organs for each exposure route. Information on flammability, reactivity and proper personal protective equipment should also be given.
Section 4: First Aid Measures
Instructions on emergency and first aid procedures are provided for each potential route of exposure, e.g., inhalation, ingestion, skin or eye contact. They should be concise and written in easily understood laymans language. If there are specific medical steps, then a Notes to Physician section is provided for this information.
Section 5: Firefighting Measures
Described in this section are the fire and explosive properties of the chemical or product components. The proper extinguishing media is given, along with any special protective equipment needed and unusual decomposition hazards. Additional information such as flashpoint, autoignition temperature and flammable limits in air are helpful depending on the chemical components.
Section 6: Accidental Release Measures
Addressed in this section are the proper responses to any spill or leak of the material. The information presented is usually intended for emergency response personnel. It describes the personal protective equipment needed and any special precautionssuch as ventilation or evacuation, cleanup methods and environmental considerations.
Section 7: Handling and Storage
This section and the following one are very important for laboratory personnel and chemical managers. This section contains guidance for minimizing potential hazards while handling and storing the material. Addressed here are requirements for types of containers and dispensing equipment as appropriate. Also covered in this section are conditions to avoid, such as temperature extremes, secondary containment, and work and hygiene practices.
Section 8: Exposure Controls, Personal Protection
Discussed in this section are the engineering controls and personal protective equipment (PPE) to be used when handling the material. The need for any ventilation or special exhaust systems is covered, along with requirements for eyewash and safety showers. Laboratory personnel should focus on PPE instructions, which provide proper eye, hand and body protection, and whether respiratory protection is needed.
Section 9: Physical and Chemical Properties
Of particular interest to chemists, the information presented here assists users in determining proper PPE, handling and storage. General appearance, odor and physical state (liquid, solid or gas) are given in addition to pH, vapor pressure and density, specific gravity, boiling point and others depending on usefulness. Any warning properties (i.e., how to detect the substance via smell, taste or feel) should be well noted.
Section 10: Stability and Reactivity
Although more important for emergency responders, users should also be familiar with the information in this section, which depicts potentially hazardous reactions or decomposition products. Examples include evolution of hazardous gases or production of heat if involved in a fire. Any incompatibilities that could lead to hazardous conditions should also be discussed here.
Section 11: Toxicological Information
Information listed in this section is drawn from both animal testing and human experience, and should include all known toxicities of the material. Included are both acute and chronic effects on skin, eyes, immune system and reproductive system, as well as from inhalation or ingestion. Data on irritancy, sensitization and carcinogenicity should also be stated.
Section 12: Ecological Information
Potential impacts should the product be released to the environment are presented here. Data on the expected environmental fate and whether degradation occurs is given, along with effects on plant, animal and aquatic life.
Section 13: Disposal Considerations
Guidance given here is intended for use by both technical and waste management peopleto evaluate waste treatment options. Usually a reference is made to follow all applicable federal, state and local regulations.
Section 14: Transport Information
This section provides information for shipping the material. In general, this means following the U.S. Department of Transportation (DOT) regulations contained in 49CFR172 and includes listing the proper shipping name, hazard classification number and description, UN identification number, and North American Emergency Response Guidebook number, as applicable. Information on international shipping may also be given.
Section 15: Regulatory Information
The chemical or products regulatory status is presented in this section. Included are the reporting requirements, threshold planning quantities, release reporting quantities and inventory status under the U.S. Superfund Amendments and Reauthorization Act (SARA); Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); Toxic Substances Control Act (TSCA) and other federal and state regulations, as applicable.
Section 16: Other Information
This section is intended for material that does not fit into any of the preceding sections; yet, the preparer feels it is pertinent. Usually included are the preparers name and contact information, revision dates, references and definitions of terms and acronyms.
As you can now see, MSDSs are complex and take some work to understand. But if you make the effort to get to know the layout and information they contain, they can provide valuable information and be a reliable asset that you turn to in times of need.
1. Deadly UCLA Lab Fire Leaves Haunting Questions, Christensen, Kim, Los Angeles Times, March 1, 2009, http://www.latimes.com/news/local/la-me-uclaburn1- 2009mar01,0,3624028.story.
2. Hazard Communication, US Department of Labor, Occupational Safety and Health Administration, Washington, D.C., February 1996, http://www. osha.gov/pls/oshaweb/owadisp.show_document?p_ table=STANDARDS&p_id=10099.
3. American National Standard for Hazardous Industrial ChemicalsMaterial Safety Data SheetsPreparation, ANSI Z400.1-1993, American National Standards Institute, New York, 1993.
http://www.ehs.cornell.edu/msds/msds.cfm : An excellent page of links to various MSDS locations and sites
http://www.msdssearch.com : Another great web page for searching MSDS