The Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard details how healthcare organizations should inform employees about any hazardous chemicals to which they may be exposed at work. A key element of the standard relates to Safety Data Sheets (SDS).
These informative documents are critical in keeping workers, patients and the environment safe. The following sections take a closer look at OSHA’s SDS requirements and how organizations can ensure consistent compliance.
What Is a Safety Data Sheet (SDS)?
A Safety Data Sheet communicates comprehensive information about a chemical, including its properties; physical, health and environmental hazards; and any protective measures or safety precautions that should be followed when handling, storing or transporting the material.
OSHA requires chemical manufacturers to provide an SDS to any entity who uses the hazardous chemical, such as healthcare organizations. In turn, healthcare organizations must ensure employees can quickly access the most up-to-date SDSs for hazardous chemicals used and stored in their workspace. The standards emphasize the importance of making SDSs detailed yet easy-to-understand. To that end, an SDS follows a prescribed, user-friendly format.
What is the purpose of safety data sheets?
A Safety Data Sheet (SDS) is your compass in the chemical landscape. Let’s break it down:
- Purpose: SDSs provide information on the hazards associated with chemicals. They guide safe handling practices and emergency procedures.
- Standardization: SDSs follow the Globally Harmonized System (GHS) criteria for classifying chemical hazards.
- Variability: While standardized, SDS content may vary among manufacturers.
- Legal Requirements: Employers must obtain SDSs for hazardous substances and make them accessible to employees.
- Training Responsibility: Principal investigators (PIs) and instructors train lab personnel on SDSs and maintain signed training records.
How Many Sections Are in a Safety Data Sheet and What Information is Included?
An SDS is divided into 16 sections that communicate the following information:
- Section 1 identifies the chemical by name, including any common abbreviations or synonyms; what the material can be used for; and the supplier’s emergency contact information.
- Section 2 outlines the chemical’s hazards as well as warning information. Manufacturers will use statements and pictograms that follow the requirements of the Globally Harmonized System—a set of internationally created and approved criteria for classifying health, physical and environmental hazards.
- Section 3 lists the product’s ingredient(s), including impurities and stabilizing additives.
- Section 4 describes first aid measures, such as initial care for an individual exposed to the chemical, acute and delayed symptoms, and any recommendations for more extensive medical treatment.
- Section 5 outlines how to contain a fire caused by the chemical, including suitable extinguishing equipment, hazards that could develop as a result of the fire, and any recommended personal protective equipment (PPE).
- Section 6 describes how to respond to spills, leaks or releases, including containment and cleanup practices to prevent or minimize exposure. Additional topics cover how to respond to spills of different sizes, proper safety precautions and emergency procedures.
- Section 7 offers guidance on chemical handling and storage, including any incompatibilities, ventilation requirements and hand hygiene recommendations.
- Section 8 covers how to minimize worker exposure, describing exposure limits, potential engineering controls and recommended personal protective measures.
- Section 9 identifies a range of relevant physical and chemical properties associated with the substance or mixture, including but not limited to appearance, flammability, odor, solubility, flash point and viscosity.
- Section 10 outlines the chemical’s reactivity hazards and stability information.
- Section 11 details toxicological and health effects, such as likely exposure routes, the effects of exposure and whether the chemical is considered to be a carcinogen.
- Section 12 provides information on the chemical’s potential environmental impact if it were released into the environment.
- Section 13 delineates proper disposal practices, including whether the material can be recycled or reclaimed and whether the same applies to the chemical’s container. Further information covers container descriptions, appropriate disposal methods and any special precautions for landfills and incineration. There is also strong language discouraging sewage disposal.
- Section 14 provides guidance on classification information for hazardous chemical shipping and transportation.
- Section 15 provides information relating to safety, health, and environmental regulations
- Section 16 provides other information not included anywhere else on the SDS, including the date of preparation and last revision.
Where Should Safety Data Sheets Be Kept?
Employers, including healthcare organizations of all types, must provide employees with ready access to SDSs for the hazardous chemicals in their workplace. There are many ways to facilitate access. For example, employers may keep their SDSs in a binder, store them electronically, or work with a third-party like Stericycle to house them in the cloud.
OSHA is not prescriptive as long as employees have immediate access to the information without leaving their work area. Even if an organization chooses to store SDSs electronically, it should have a back-up available in case of a power outage or other emergency.
Are Safety Data Sheets Necessary for Household Items?
OSHA does not require an SDS for household consumer products used in the workplace provided they are used as a consumer would use them, following the same purpose, duration and frequency.
If an employee exceeds this level of exposure, then an SDS is warranted.
Do Employees Exposed to Hazardous Chemicals Need Training?
Employees should receive training when they are first assigned to work with a hazardous chemical to make sure they understand the risks and the practices that can keep themselves and their co-workers safe—before they start interacting with the material. They should also receive training when a new hazardous chemical is introduced into the work area if they have not been trained on that material to date.
Hazardous Chemical Training Requirements
Training must include more than just reading the SDS. Proper education describes the dangers associated with the chemicals in the work area, what can be done to minimize risk, how to respond to a spill, and how this work relates to the Hazard Communication Standard as a whole.
Training should be accessible and easy to understand. It should also include an opportunity for employees to ask questions to ensure they fully comprehend the information presented.
Organizations can conduct training by categories of hazard, such as carcinogens, sensitizers, and acutely toxic agents, so staff see the relationship between chemicals and have a broader understanding of how to remain safe. They can also weave SDS training into larger OSHA training as long as OSHA’s requirements are fully met.
How to Ensure Your Organization Is Compliant with OSHA’s SDS Requirements
A first step in complying with OSHA’s SDS requirements is to recognize the hazardous chemicals a healthcare organization has onsite. This may involve conducting a room-by-room inventory and listing all the chemicals present.
Once an organization has a detailed list, staff can check that the required SDSs are available and accessible. An organization may want to designate a specific person(s) responsible for obtaining and maintaining the SDS. If a required SDS is missing, the designated employee should ensure that it is made available.
It is also important to check that SDSs are current. Manufacturers will send an SDS the first time a chemical is delivered or after there is a change to the document. When a new SDS arrives, staff must compare it to the existing one to determine what has changed. The organization should have processes for broadly communicating any new information to staff.
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