Q: Who needs SDS?
A: Anyone who is shipping chemicals.
Every time any company or supplier ships chemicals anywhere in the country or around the world, it is mandated that they provide a Safety Data Sheet. To be in compliance with the regulatory bodies nationally and internationally, they must provide this sixteen-section document when shipping a chemical or chemical mixture from a facility to another location… to a warehouse… to any destination.
Also, if you repackage or re-batch chemicals, you need to generate your own SDS, and not just use the one provided by the manufacturer.
If you are a distributor, you can simply use the manufacturer’s SDS, but for marketing purposes you may want to put your own Logo and contact information on it.
Q: What is GHS?
A: GHS or The Global Harmonized System (GHS), is an internationally recognized standard for classifying chemicals created by the United Nations, that most countries follow, including the US. While there are variations in format from country to country, they all follow the basic GHS classification of all the chemicals. This creates a common understanding of what substances are involved and their level of toxicity and hazard.
Q: Are all chemicals considered hazardous?
A: Not all chemicals are created equal, and many require specific handling to avoid unnecessary accidents that expose workers to toxic hazards. That’s where Safety Data Sheets (SDS) come in. Broadly speaking, all chemicals can be separated into two categories: hazardous and nonhazardous. While there is no definitive list of hazardous and nonhazardous chemicals, OSHA maintains a set of GHS-compliant standards to determine a chemical’s classification and thus determine whether or not a chemical needs an SDS. According to HazCom 2012, employers are required to have an SDS readily-accessible for all chemicals deemed hazardous.
Q: Which chemicals are considered hazardous?
A: A hazardous chemical is one that poses a health hazard, a physical hazard, or an environmental hazard. While the definition itself is simple, the criteria is less so.
Health hazards are identified by how the body reacts when exposed to it. A chemical is a health hazard if exposure to it results in at least one of the reactions listed in Appendix A to 29 CFR 1910.1200 – Health Hazard Criteria:
- Acute toxicity
- Skin corrosion or irritation
- Serious eye damage or eye irritation
- Respiratory or skin sensitization
- Germ cell mutagenicity
- Reproductive toxicity
- Specific target organ toxicity (single or repeated exposure)
- Aspiration hazard.
A chemical may also pose a health hazard if the classification criteria are not met, but the chemical still causes health effects such as slight irritation or nausea, but do not reach GHS classification criteria.
Physical hazards are identified by the physical properties and reactivity of the chemical itself. If a chemical has any of the properties listed in Appendix B to 29 CFR 1910.1200 – Physical Hazard Criteria, it is a physical hazard:
- flammable (gases, aerosols, liquids, or solids)
- oxidizer (liquid, solid or gas)
- self-reactive; pyrophoric (liquid or solid)
- organic peroxide
- corrosive to metal
- gas under pressure
- in contact with water emits flammable gas.
An environmentally hazardous chemical is one that has the potential to drastically and detrimentally disrupt the natural environment. GHS classification dictates that a chemical is an environmental hazard if it can cause damage specifically to either the aquatic environment (acute and chronic) or to the ozone layer.
Chemicals that meet any of the above criteria are hazardous and must have an accompanying SDS.
Learn more about the Hazard Communication Standard Pictogram here.
Q: What If I am not sure if a chemical is hazardous?
A: If you have any doubts about whether a chemical is hazardous or nonhazardous, it is best to stick to the age-old adage of “better safe than sorry” and make an SDS because there can be serious consequences for not having an SDS for a hazardous chemical. For one thing, OSHA imposes hefty fines for noncompliance. More importantly, however, the absence of an SDS can lead to unnecessary exposures that leave your workers vulnerable to injury.
Caution is the name of the game when it comes to all things chemical. When in doubt, generate an SDS.
Q: Who is responsible for SDS?
A: Three positions in your firm will have primary concern for your SDS.
- The CEO or Owner. This person wants to achieve efficiencies in creating and delivering SDS, guarantee safety of employees and customers, and avoid exposure to risk.
- The Environment Health and Safety lead. This individual’s concern is to mitigate human error in the authoring of the SDS, guarantee safety, and reduce the cost of generating and managing the SDS and related chemicals. They are looking for greater accuracy and efficiency so they can focus on the many other things they are responsible for.
- The lab chemist or technician: They are confident that the SDS they have generated are accurate but they may be seeking a confidence review from a second source to avoid releasing an SDS that is non-compliant.
Q: What is the key to creating an accurate, GHS-compliant SDS?
A: The key is the formula itself. That is the first thing to check. Of course, it has a name… and a manufacturer… the basic things, but the main thing that you really need to get started is the formula itself, which is Section 3 in the SDS standard form. The mixture is a set of chemicals with their CAS numbers. A CAS number is a universally recognized, unique and unmistakable numerical identifier of each chemical assigned by the Chemical Abstracts Service (CAS) to every chemical substance. It currently identifies more than 183 million unique organic and inorganic substances and 68 million protein and DNA sequences. (https://www.cas.org/about/cas-content)
And a customer would also use the percent weight, so you would know how much of the chemical is in the mixture. That will determine its classification. If a customer cannot locate the CAS number and the percent weight, the project should be put on hold until they do. Once they do, work can start. If we have a customer that is requesting we generate the SDS and has a concern about revealing their formula to us—it is their intellectual property, their proprietary information–we assure them of our confidentiality and if needed, sign an NDA.
Here’s a link to a blog that answers this question in detail.
Q: What are common customer challenges?
A: Here is a blog that answers this question more completely.
Q: Why can’t I just go online and get an SDS?
A: Some companies who do their SDS themselves will go on the Internet and find an SDS that is close to what you’re doing and then put your name on it. But this is not a good strategy because there are differences between your specific mixture and formula and a generic “close to what you need” SDS. You can be confident if you author SDS specific to your product and your mixtures.
Q: What would be the benefit of us not using our own “DIY” solution for authoring SDS?
A: When you develop SDS, there are always little details you need to keep track of like regulation changes, version changes, and different requirements for different countries and/or languages. With our software, you don’t have to have these details front of mind because we address them for you. For example, if you needed to do an SDS for Canada there’s a requirement of English and French and our software will create those two different SDS for you.
Q: What is the Purple Book?
A: The purple book is the GHS compliance book that is some 600 pages. Our software‘s algorithm works in such a fashion that it will pull all the information you need for all 16 sections and make certain that it’s customized for your product ingredients and mixture formula in a fraction of the time so you can go do the things that only you can do. If you choose to do it yourself, you will need to be intimately familiar with the purple book.
Q: Can you help us with small nuances?
A: Many customers make special blends on a regular basis and need new SDS constantly. We found with our customers that we can do the nuances very quickly in the SDS so that that particular formula is clear but it doesn’t take that much time for our system to generate the various blends that you were trying to create.
Q: For SDS for other countries is the only concern to just get the language translated properly?
A: Translation is important, but it’s not just a matter of translation. There are some big differences in various countries’ SDS requirements, and our software will develop the SDS form with all of the correct regulations and requirements identified for that region or country.
Q: Am I at risk if I have SDS that are five years old?
A: Industry best practice is to update your SDS every three years. To save you the hassle of keeping track of routine SDS updates, our team at Quantum will alert you when it’s time to update your SDS.
Q: How can you help me be certain that I’m compliant?
A: We build a buffer between you and noncompliance! With our software, you can be assured that the SDS you get from us will be GHS-compliant. We update the software almost on a daily basis to make sure that it represents current requirements. We respond to your customer service questions within 24 hours, often sooner. Annually, we are in touch with you to see if there’s any functionality or service that you need to advance your safety and compliance. We also check to make certain that none of your SDS are older than three years as is recommended by industry best practice and if they are, that they are updated.
Q: What kind of customer service do you provide?
A: When we receive an inquiry from a customer, we will respond within 24 hours, but more often it will be within the hour. You aren’t just a number to us. We make certain we understand our customers’ specific needs and guide them to have a successful experience with our software and services.