Many readers have asked for help in translating material safety data sheets (MSDSs) into usable English. I have hesitated, because I knew big changes on MSDSs were about to occur. Now this change is coming into effect — and we need to talk!
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n March 26, 2012, The Department of Labor published a final rule to modify the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard. The new rule requires manufacturers and employers to conform to the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and to a new MSDS format. The rule has been in effect since May 15 of 2012, and the rest of the schedule of implementation is as follows: • December 1, 2013: Employers are required to train employees on the new labels and material safety data sheet (MSDS) formats. This means if you use ceramic chemicals on the job, your employer must provide training for you on the new MSDSs and label symbols.
employers must write up these changes in their OSHA hazard communication program, and update the training of their employees with any new information about hazards of their materials.
INDUSTRY ACCEPTS THE NEW REGULATION? Doesn’t it seem odd that OSHA has what is essentially a new regulation without any talkback from industry? Usually, when OSHA proposes a rule change, industry and OSHA engage in a battle for a few years. Most often OSHA’s new regulation is killed, which explains why we still have 1971 air quality standards.
• June 1, 2016: Employers must update all employees on the alternative workplace labeling and hazard communication programs, and provide additional employee training for newly identified physical or health hazards. This means
The new rule means that those almost useless and confusing MSDSs should be improved. For example, our MSDSs commonly use the phrase “not listed as a carcinogen” when what should really be said is the substance “has never been
The rest of the world does not accept our assumption that untested chemicals are nontoxic. Instead, most countries base their worker and consumer safety laws on the Precautionary Principle which says in the absence of actual data, chemicals cannot be assumed to be safe. U.S. manufacturers and OSHA are not quite ready to give up our crazy system of misinforming workers and consumers. By comparing the original United Nations version of the MSDS with OSHA’s, you will see how they do this.
ORIGINAL SDS REQUIREMENTS The MSDS version used by most of the rest of the world requires that actual test data for toxic effects, if known, be reported in Section 11, as follows: A4.3.11 SECTION 11 — Toxicological information Under GHS classification, the relevant hazards for which data should be provided are:
(a) acute toxicity; (b) skin corrosion/irritation; (c) serious eye damage/ irritation; (d) respiratory or skin sensitization; (e) germ cell mutagenicity; (f) carcinogenicity; (g) reproductive toxicity; (h) specific target organ systemic toxicity — single exposure; (i) specific target organ systemic toxicity — repeated exposure; and (j) aspiration hazard. If data for any of these hazards is not available, they should still be listed on the MSDS with a statement that data is not available.* The most important line is the one I’ve made bold at the end of the section. This requires the manufacturer to inform users when the tests have not been done. For example, line (f) for carcinogenicity would either tell you the results of animal cancer tests, or the blank must say “no data available.” This means anyone can glance down the list and see whether or not the substance has been tested for cancer.
OSHA’S REQUIREMENTS Now let’s compare that with the OSHA description of Section 11: continued on next page
CLAYTIMES·COM n WINTER / SPRING 2013
• December 15, 2015: GHS labels must be on all containers that are shipped by chemical manufacturers or importers. This means the makers of our glazes, glaze chemicals, clays, and other products will have to change the labels soon.
Yet this change produced no backlash. The reason: either these changes are made, or our manufacturers must give up the idea of exporting our products. The new labels and MSDS have already been instituted in most of the rest of the world including the European Union, Japan, and China. As usual, the U.S. lags behind most countries in chemical safety.
tested or evaluated for cancer effect.”! Worse, many manufacturers choose to label untested chemicals as “nontoxic”, simply because they have not yet been shown to be toxic!
Studio I Health & Safety
BY MONONA ROSSOL
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