MSDS SDS Differences Training by Penn State University

Pesticide Education Program
Globally Harmonized System (GHS)
Change from
Material Safety Data Sheet (MSDS)
to
Safety Data Sheet (SDS)

Objectives
• History of GHS
• Major Changes Under GHS
• What Do You Need to Do
• Step by Step Compliance

• An international mandate to harmonize labels
was adopted at the United Nations
Conference on the Environment and
Development (UNCED) in 1992 in Brazil:
– A globally-harmonized hazard classification and
compatible labeling system, including material
safety data sheets and easily understandable
symbols, should be available, if feasible, by the
year 2000.
History of GHS

In March 2012, Occupational Safety
and Health Administration (OSHA)
published a final rule to align its
Hazardous Communication
Standards (HCS) regulations with the
Globally Harmonized System (GHS)
of Classification and labeling of
chemicals

The primary goal of GHS is improved
protection of human health and the
environment by providing chemical
users and handlers with enhanced
and consistent information on
chemical hazards.

The GHS is based on major existing
systems for industrial chemicals,
pesticides, consumer chemicals, and
chemicals in transport, but
implementation of the GHS would
require some changes in all existing
systems in order to achieve
harmonization.

However, it is important for growers
who use Federally regulated pesticides
to note that the Environment Protection
Agency (EPA) has NOT yet moved to
amend its pesticide labeling regulations
under the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) to align with
the GHS.

Under the HazCom 2012, the MSDS
will be replaced with a Safety Data
Sheet (SDS).
Why the switch from MSDS to SDS?

Why the switch from MSDS to SDS?
• Before the HazCom 2012, there were several
acceptable MSDS formats. OSHA’s adoption of
Global Harmonization Standards (GHS)
requires the use of a single format.
• All SDS will have 16 sections that appear in a
specific order.

Major Changes Under GHS

• MSDS to SDS Format
• Labeling Requirements/Pictograms
• Hazard Classification
Changes

• MSDS to SDS Format
– MSDS will now be referred to as Safety Data
Sheets
– There is now a specified 16-section format that
must be followed.
Changes

Section 1
Identification of Substance and Supplier

Section 2
Hazard Identification

Section 3
Composition/Information on Ingredients

Section 4
First Aid Measures

Section 5
Firefighting Measures

Section 6
Accidental Release Measures

Section 7
Handling and Storage

Section 8
Precautions to Control Exposure/Personal
Protection

Section 9
Physical and Chemical Properties

Section 10
Stability and Reactivity

Section 11
Toxicological Information

Section 12
Ecological Information

Section 13
Waste Disposal Consideration

Section 14
Transportation Information

Section 15
Regulatory Information

Section 16
Other Information

Pictograms

Pictograms
• Health Hazard
– Carcinogen
– Respiratory sensitizer
– Reproductive toxicity
– Target Organ toxicity
– Mutagenicity
– Aspiration toxicity

Pictogram
• Flame
– Flammables
– Self-Reactives
– Pyrophorics
– Self-Heating
– Emits flammable gas
– Organic peroxides

Pictograms
• Exclamation Mark
– Skin and eye irritant
– Skin sensitizer
– Acute toxicity
– Narcotic effects
– Respiratory tract irritant

Pictograms
• Gas Cylinder
– Gas Under Pressure
• Flames Over Circle
– Oxidizer

Pictograms
– Corrosion
• Corrosives
– Skull and Crossbones
– Acute Toxicity (Severe)

Pictograms
• Exploding Bomb
– Explosives
– Self-Reactive
– Organic peroxides

Pictograms
• Environment
– Aquatic Toxicity

• The definitions of hazard have been changed to
provide specific criteria for classification of health
and physical hazards, as well as classification of
mixtures
• These specific criteria will help to ensure that
evaluations of hazardous effects are consistent
across manufacturers, and that labels and safety
data sheets are more accurate as a result
Hazard Classification

Will the change require that both and MSDS
and an SDS be kept for the same product?
• For compliance with the new OSHA HazCom 2012
regulatory requirements, maintaining both an MSDS
and a SDS for the same chemical is not necessary.
• As the SDS becomes available for individual products,
they will replace the existing MSDSs.
• Although there is no requirement to keep the older
MSDS once it is replaced with an SDS, a good
management practice would be to keep an electronic
copy on file, especially if existing stocks of the chemical
were purchased under the older MSDS.

Will the change require that both and MSDS
and an SDS be kept for the same product?
• When the chemical in question is a pesticide
and the content of the MSDS and the SDS
differs, a copy of both documents must be
maintained to ensure compliance with OSHA
HazCom 2012 and FIFRA which regulates
pesticide products.

The differences between EPA’s
current requirements and the GHS
are related to classification criteria,
hazard statements, pictograms, and
signal words.

For example, FIFRA pesticide product
labels may contain the following signal
words: of “Danger Poison with the skull
and crossbones graphic,” “Warning,” or
“Caution” depending on the toxicity
level of the product, and “Danger” for a
product that may be a potential skin or
eye irritant.

The GHS uses only two signal
words, “Danger” and “Warning.”

How this may cause a problem for
example is the label of a chemical
that has an oral LD50 of 550 mg/kg
bears the signal word “Caution”
under current FIFRA labeling
practices but would require the
signal word “Warning” under the
GHS Safety Data Sheet format.

For pesticide products, FIFRA labels
approved by EPA pre-empt OSHA’s
label requirements, but not the
requirements for SDS and worker
training (except for certified
applicators and agricultural workers
for whom EPA has training
requirements).

EPA realizes that this may require
users of the SDS that are prepared for
pesticide products to become familiar
with two different systems, at least
until the agencies’ requirements are
harmonized.

As a result, EPA issued guidance in the
April 20, 2012 Federal Register to
manufactures so that when changes
are made to the SDS to meet the
OSHA requirements, the new SDS
format will also be in compliance with
the pesticide regulations under FIFRA.

HazCom 2012 Compliance
Dates and Deadlines:
There is a 3 year phase in period
through 2016

• December 1, 2013 –
– Employers must train employees on how to read
GHS formatted labels and SDS’s.
– Changes to labels are probably more substantial,
however, employees need to understand where
to find information on the SDS.

• 2013 – 2015 On an Ongoing Basis –
– Employers should replace existing MSDSs with
new SDSs as they become available.
– For pesticide products, employers must be sure
to determine if there are any differences
between the MSDS and SDS. If differences exist,
a copy of the MSDS must also be maintained to
be in compliance with both HasCom2012 and
FIFRA.

• June 1, 2015 – Chemical manufacturers and
distributors should have completed their
reclassification of chemicals and be shipping
GHS formatted SDS and labels with their
shipments.

• December 1, 2015 – Distributors have an
additional 6 months beyond the June 1, 2015
date to pass along manufacturer labels and
SDSs in the older formats. However, beyond
December 1, 2015, all MSDSs and labels in the
U.S. should be in compliance with HazCom
2012 provisions.

• June 1, 2016 –
– Employers should be fully compliant with
HazCom 2012. That includes making any
necessary updates to their HazCom program,
training employees on any newly identified
chemical hazards (identification of new hazards is
likely during the reclassification process chemical
manufacturers undertake), and updating SDS
libraries and secondary labels.

This presentation was created in partnership with the
Pesticide Education Program, Penn State Cooperative Extension;
and the Pennsylvania Department of Agriculture.
For more information on this and other resources, please visit
extension.psu.edu/pested
Where trade names appear, no discrimination is intended, and no endorsement by Penn State Cooperative Extension is implied.
Penn State is committed to affirmative action, equal opportunity, and the diversity of its workforce.
© The Pennsylvania State University 2012 November 2012

MSDS SDS Differences Training by Penn State University

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