Material Safety Data Sheets exposed

This article outlines the most pertinent yet commonly misunderstood features of a Material Safety Data Sheet (MSDS) and sheds light on the legislation surrounding these features, the requirements of the supplier and the information that should be reviewed prior to accepting the use of a chemical substance in the workplace. It follows the new 16 Header MSDS Format in accordance with the National Occupational Health and Safety Commission's (NOHSC) Code of Practice for the Preparation of Material Safety Data Sheets 2nd Edition [NOHSC:2011(2003)].

When people think of chemicals, they usually think of particularly harmful substances, such as the highly toxic hydrofluoric acid, exposure to which can be lethal if first aid is not administered quickly and correctly. Not may people realise that practically harmless substances, such as sunscreens and barrier creams, also qualify as chemicals. Often, the need to use hazardous chemicals cannot be avoided, and it is because of this that significant legislation exists in Australia to protect the safety of workers.

Failure to meet legislative requirements can result in substantial fines and operational downtime. Recently, fines as large as $50,000 have been imposed on a number of organisations for non-compliance - such as failing to provide material safety data sheets or not conducting risk assessments on hazardous substances.

Although fines can be avoided by obtaining and storing the required information, is the safety of employees really being considered if this information is simply placed in a folder and locked away in a cupboard, without ever being reviewed or understood by the workers who are at risk?

Material safety data sheets, the regulatory and industry answer to providing employees with hazard and safety information on chemicals, exist for all types of chemical substances.

Most employers are aware of their requirement to obtain an MSDS for all hazardous substances and dangerous goods present in the workplace, and to ensure they are readily available to all employees. However, not all employers and employees understand the information contained in an MSDS nor take the time to review the document before using a chemical substance.

Globally harmonised 16 header format

The 16 Header MSDS Format arranges the safety information for a chemical substance into 16 headings.

Hazards identification (Section 2)

Arguably the most important information contained in an MSDS is the hazard classification, which includes a statement of the overall hazardous nature as defined by NOHSC and the associated Risk and Safety phrases. The chemical substance should be classified as either 'Hazardous according to the criteria of NOHSC' or 'Non-Hazardous according to the criteria of NOHSC'. Far too frequently, the hazards statement is either absent or incorrect. If this is the case, it is important to contact the supplier of the MSDS to ensure that the appropriate information is provided.

If the material is classified as hazardous, it is a legal requirement for both the supplier to provide an MSDS and the employer to obtain it. Furthermore, employers must also keep a register of hazardous substances, provide adequate labelling, and perform regular risk assessments. Although there is no legal requirement for the supplier to provide an MSDS for non-hazardous materials, it is considered good practice to do so.

While the hazard classification deals with harm to health, another important feature of the MSDS is the inclusion of dangerous goods information, which details the dangerous chemical or physical properties associated with a chemical substance. Information should state that the chemical substance is either 'Classified as a Dangerous Good by the criteria of the Australian Dangerous Goods (ADG) Code' or 'Not classified as a Dangerous Good by the criteria of the ADG Code'. As well as this, the MSDS must also present transport information in Section 14.

Further legislative obligations exist for dangerous goods. These may include the requirements for placarding or signage, segregation, separation, first aid facilities, fire fighting, dangerous goods manifests, transport and bunding. When in doubt, it may be beneficial to acquire the services of a dangerous goods expert to visit your workplace and ensure your legislative requirements are met, particularly where large amounts of dangerous goods are stored.

First aid measures (Section 4)

First aid information should describe the initial care that can be applied prior to receiving medical attention.

The infamous death of a laboratory technician exposed to hydrofluoric acid 10 years ago highlights the importance of reviewing the appropriate first aid measures, and being adequately prepared. In this case, the chemical was mistaken for the less toxic hydrochloric acid and the essential calcium gluconate gel first aid treatment was not made available to treat the victim once the chemical was spilt on the skin. Consequently, the fluoride component of the acid was able to enter the victim's blood stream, eventually leading to a painful death from multiple organ failure of the lungs, heart, liver and kidney.

Exposure controls and personal protection (Section 8)

Exposure Controls and Personal Protection details the measures that can be taken to limit exposure to hazardous substances, including the use of personal protective equipment (PPE). PPE is considered a last resort in the control of chemical substances; however it may be essential in some cases, especially emergencies. Often an MSDS will list the requirement to wear PPE such as gloves, safety glasses and respirators, but will not suggest which materials or types should be worn. It is crucial to be fully aware of the particular types of PPE required in order to provide employees with adequate protection from chemical substances.

In the example of hydrofluoric acid, Ansell's Specware Chemical Handling Guide recommends chemical resistant barrier gloves, unsupported neoprene gloves or unsupported nitrile (Sol-vex) gloves. However, in this case some glove types, including supported polyvinyl alcohol (PVA), are not recommended and may provide little to no protection. The same is applicable to respiratory protection, where several particulate and vapour/gas filter types exist, each of which provides adequate protection against certain chemical substances and not against others.

Physical and chemical properties (Section 9)

Physical and chemical properties are another essential element of an MSDS that must be reviewed prior to introducing a chemical substance in the workplace. Aside from critical data such as the appearance (colour, physical form, shape), vapour pressure and solubility, it is essential that an understanding of the pH and flammability/flashpoint be established.

In particular, the supplier may overlook extremes of low or high pH when evaluating the hazardous substance or dangerous goods classification. Similarly, the flammability and flash point (also represented in Section 5) must be understood, particularly for combustible substances (with a flash point of less than 61°C) that may constitute a greater hazard when stored in bulk (as is the case with diesel fuel).

Advances in MSDS management

Although only certain features of an MSDS have been discussed here, it is important to recognise that all information presented in an MSDS can improve the end users' understanding of the health and safety issues associated with a substance. Accurate Australian supplier contact details, detailed composition information, toxicological information and precise ecological effects and disposal techniques can all influence the outcome of a potentially hazardous situation, and it is because of this that Australia has advanced to the new 16 Header MSDS format.

While currently some suppliers may not provide MSDSs in the correct format, or may omit relevant information, this will soon change as employers and end users of chemical products become better educated as to the requirements of an MSDS, and more confident in demanding those requirements from suppliers.

Furthermore, although the manufacturer is required to review the MSDS every five years, the information contained in an MSDS can change any time as new information becomes available on a chemical. It is therefore good practice to form a relationship with your major chemical suppliers to ensure that you receive a revised MSDS as soon as it becomes available.

Employers can provide MSDSs and additional safety information in many ways, from third-party reports, transcribed data and hard copy reports through to electronic databases. Electronic databases can eliminate the hard work of MSDS management and often have added functionality to ensure that companies meet all their legislative obligations - such as risk assessments, stock registers, placarding and labelling.

Regardless of the medium in which the information is provided, it is essential that employees understand the hazards associated with chemical substances and have ready access to safety information that allows them to take the appropriate measures to protect themselves. Ensuring that workers are aware of the hazards posed by the use of chemical substances through training and education can prove the difference between life and death - a fact illustrated only too well by the above example of hydrofluoric acid.