Coping with SDS’s Prepared for the OHSIG Conference 2011 Dr. Birgit Rahm Datachem LTD
Coping with SDS’sSDS’s and compliance with HSNO Legal Requirements & Responsibilities NZ requirements International SDS’s Writing your own SDSs
Legal requirement (HSNO) - Level 2 documentation requirementSuppliers of Hazardous Substances • Obligated to provide SUPPLIERS HSNO compliant SDS’s.Users of Hazardous Substances • Need information – SDS • Know the hazards PERSON in CHARGE • Safe use/PPE/Exposure control • Safe storage • Safe disposal. • etc
Purpose of a Safety Data Sheet - Safety for users and the environment• A SDS is an important part of the responsibility of an employer to ensure a safe working environment• SDS provides information on safe use and emergency management of a substance.• Must be available in 10 Minutes.
Responsibility as a Supplier ofHazardous SubstancesRegulations: HSNOHazardous Substances (Identification) Regulations 2001Hazardous Substances (Emergency Management)Regulations 2001Hazardous Substances (Disposal) Regulations 2001 HSEHealth and Safety in Employment Act 1992How to?Code of Practice – NZCIC16 Header SDSComply with Group Standards
Who has the responsibility?From Group standard:In each place of work where the substance ismanufactured, stored or used, the person in chargeof the place must ensure that every person handlingthe substance has access to a safety data sheet ofthat substance
How do I know if the SDS is NZ compliant? Checklist: • 16 headers • NZ contact details & Emergency Tel# • Group standard or HSNO approval number • HSNO Classes • Hazard & Precautionary statements • Regulatory Information (section 15) • Not older than 5 years.
Checklist:Important:• Ingredient information• Comprehensive First Aid Information,• Emergency response information,• PPE and WES information,• Tox and Ecotox information,• Transport information
USERS of Hazardous SubstancesKeeping up to date with SDS’sFIRST STEPS:• Inventory – what chemicals do we have on site?• SDS’s - For all hazardous chemicals on site?• Are the SDS’s readily accessible?• Are they current NZ compliant SDS’s?
Coping with SDS’sBuilding up the SDS libraryDon’t have NZ compliant SDS?Ask supplier for a NZ compliant SDS.Considerations:• Don’t use that chemical• Change supplier• Prepare your own SDS and compliance record• Use SDS/SDS authoring service• Can I group my SDS – generic SDS’s
Suppliers of Hazardous SubstancesSDS’s from other countries are not acceptable.
Suppliers of Hazardous SubstancesSDS’s from other countries are not acceptable.NZ information must be added to SDS.NZ contact details and Emergency tel noHSNO classification –see Compliance RecordHazard and Precautionary statementsRelevant controls
Compliance Recordsrecord of how HSNO classification has beenassigned (calculations)must be available for inspection if requestedby a HSNO enforcement officer.include HSNO approval (approvalnumber, group standard)
Preparing your own SDSFirst stepsCollect information • International SDS available? • Full Formulation available? • Physical data (flashpoint, appearance etc) • Specific risks and hazards of the substance
Preparing your own SDSAssign HSNO Classification • Information on each ingredient • Assign a group standard. • Compliance record
Preparing your own SDSFurther Information • Workplace Exposure standards • PPE • Spill procedures • HAZCHEM code • Disposal • Transport Information
Considerations• Grouping your substances• What happens to two pack substances?• Combining International & NZ information• Safety information (Safety Cards)
Coping with SDS’s• Finally remember • A SDS is a living document and must be reviewed at least every 5 years or when new information comes to hand. • The requirement is NOW and • There are no exemptions (cf Labels)
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