From MSDS to SDS
The Globally Harmonized System of Classification and Labeling of Chemicals, hereafter called the GHS, is a UN-approved system that aims to improve safety and documentation for laboratory chemicals across all nations. Although laboratory-level labeling was mandated by OSHA to be completed by June 1, 2016, due to the massive levels of change required it is not implausible to believe that many labs are struggling to finalize changes in an efficient manner. Additionally, upgrades to existing systems are vital to improve lab efficiency. A comprehensive strategy and organizational structure is necessary for a successful transition to the GHS standards.
For the typical laboratory management team, the primary goals of your transition will be to implement a successful update from the old Material Data Safety Sheets (MSDS) to the newer Safety Data Sheets (SDS) and to guide laboratory scientists and staff in proper labeling of hazardous chemicals and mixtures. This article aims to lay out a basic system for labs of various sizes and organizational structures to make the transition to SDS easier.
Why is the GHS necessary?
Before you begin the necessary work to update to the new system, you may wonder exactly why you are making these changes. Oftentimes, the old MSDS seem adequate. However, the more streamlined format of the SDS allows for quicker interpretation and more efficient cleanup by safety staff in the event of an accident. Additionally, the new systems help with international trade, should the lab group in question be planning to export chemical mixtures.
SDS storage styles
Existing MSDS systems are likely stored on paper sheets in binders. Modern technology, however, is not limited to paper systems, and a digital SDS ledger could be a tempting solution to track all new changes. All the SDS data will be downloaded from the supplier’s web page, after all. Be aware that while this is acceptable, all employees must have ready access to these sheets during work shifts. To comply with ready access, any computer system used for SDS must have open access for all employees. A computer that requires a login would not be accessible to those who do not know the password, for example. There must also be adequate backup measures in case of Internet failure or a power outage. It may be useful to share all SDS documents on a cloud storage system, but in case of an Internet failure, it is advisable to have a local copy on all designated SDS access computers. Additionally, it should be noted that ready access means an employee should not need to do a web search for the product to find the SDS. This means that even if a lab is going the web-only route, it should still supply an SDS repository in its systems. Be sure to update this regularly, such as when the lab receives orders and again monthly to ensure all files are up to date.
If your facilities do not have power generators, you should take the time to produce a physical paper copy as well. This could be a very time-consuming process, so be sure to allow adequate time to complete all the necessary steps. A recommended system is to go in alphabetical order along your chemical inventory sheet, save the files to the computer system first, and then print them. Depending on the company by which the chemical is manufactured (it is a requirement to have the SDS from the company that manufactured the product) and the quality of your printer, this whole process could take up to ten minutes per SDS. Even when using double-sided printing techniques, your lab should prepare to be using four to five sheets of paper per SDS printed, so have plenty of cheap paper on hand. After stapling and three-hole punching each SDS entry, try to resist cramming your binders full since you will want to leave ample space for new chemicals in the future. Be sure to staple each entry together before adding it to your binders so it won’t be confusing to go through them later. Last, new chemicals should be put at the top of the queue during this process so they are not skipped over (e.g., the lab acquires ethanol while the staff member working on SDS updates is working on formaldehyde).
Larger lab groups
In general, larger lab groups are going to have the most trouble updating to the new system. The sheer size of the chemical inventory alone can cause trouble. Since larger lab groups have more staff, it makes sense to break up the work among several people or have several staff members take shifts at a single computer between experiments. Care must be taken to be extra methodical and have inventory lists available when using this method to ensure no items are skipped. Consider splitting up the list among several staff members who have their own segments that they are responsible for (e.g., Jake gets “AC,” Janet gets “D-G”). It is important to keep file-naming conventions the same for all employees working on upgrading the system.
Sprawled laboratories with multiple rooms on several floors and/or buildings, such as at a university, will have unique challenges during this process. Since nobody wants to redo any part of the list, a good first step is to consolidate all chemical inventories from each section and eliminate duplicates, then divvy up the remainder of the list to connected subsections. Since lab sections are likely to share chemicals with one another from time to time, it would be advisable for all interconnected systems to have the same copy of the SDS list.
Notes for subgroup managers
Ultimately, each manager of a laboratory subgroup should be responsible for his or her own section’s inventory. This means double-checking that all used chemicals are represented in the SDS log and ensuring that either all computers for the section are connected to a generator in case of Internet failure or there is a printed copy of the section’s chemicals made available. If different subsections regularly share chemicals, it may be worth the time to go ahead and prepare the SDS entries for connected labs in advance instead of worrying about remembering to do so later.
Small laboratory groups face a different set of challenges. Often, a smaller group may use just as many chemicals as larger groups, but it has fewer people-hours available to perform the task at hand. If careful planning cannot fix this problem, the smaller lab with extra monetary resources can consider hiring a temporary worker or contractor for this task. Avoid the temptation to pay for access to an online SDS database, as the SDS information should already be available on the company’s website. The important thing now is to have the information available in an offline format.
What if a chemical has no SDS data online?
Periodically, a lab may find itself with a chemical that does not have an online SDS available. This could be due to either its being from a now-defunct company or the company simply not having upgraded from the old MSDS yet. As long as the lab still possesses the original MSDS, there will be fewer issues later. Making an effort to pair the MSDS with an SDS of the same chemical from an active company along with clear documentation may be the best route. Ask to see whether anyone is actively using the chemical or plans to; if not, perhaps it is time to dispose of it. Rarely, even an established company like Fisher will still have an MSDS up on its website. Simply make a note of these issues and compile a list of chemicals with their respective companies; emailing or calling them with a list of chemicals still needing SDS will help both the lab and the companies stay in compliance.
One of the most important challenges for all labs undergoing the change to the new SDS system will be staying compliant. Ensuring that multiple, up-to-date copies exist of all SDS logs is essential. To avoid wasting time with replacing printed SDS after an emergency such as a fire, flood, or spill, consider purchasing easily accessible weather-proof storage bins. If the lab has outsourced the updating process, be sure to obtain documentation from the contracted individuals responsible for the upgrade on the best ways to keep a consistent and logical format for new entries. Finally, even when switching to updated sheets as you get new chemicals in, always be sure to hold onto old SDS and MSDS information so the lab can provide documentation that previous lab members were aware of the risks of working with those chemicals and had easy access to the corresponding safety sheets.
For more information about the details of upgrading to the GHS system for SDS and other matters, check out:
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