Technician Regulation and Safety Training

***NOTE -- To fully comply with OSHA Hazmat Communication requirements, your employer must provide on-site information concerning the types of chemicals you might be exposed to and the location of the Safety Data Sheets (formerly MSDS) in conjunction with this class. If you have any questions at any time during this program, you should direct them to your employer.

Label and MSDS Changes
GHS - Globally Harmonized System of Classification
and Labeling of Chemicals

This information has been taken directly from the Department of Labor's, Occupational Safety and Health Administration (OSHA's) web site at http://www.osha.gov/dsg/hazcom/ghs.html.

The GHS is an acronym for The Globally Harmonized System of Classification and Labeling of Chemicals. The GHS is a system for standardizing and harmonizing the classification and labeling of chemicals - worldwide. It is a logical and comprehensive approach to:

Defining health, physical and environmental hazards of chemicals;
Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria; and
Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS)..

Many countries already have regulatory systems in place for these types of requirements. These systems may be similar in content and approach, but their differences are significant enough to require multiple classifications, labels and safety data sheets for the same product when marketed in different countries, or even in the same country when parts of the life cycle are covered by different regulatory authorities.

This leads to inconsistent protection for those potentially exposed to the chemicals, as well as creating extensive regulatory burdens on companies producing chemicals. For example, in the United States (U.S.) alone, there are requirements for classification and labeling of chemicals in place for the Consumer Product Safety Commission, the Department of Transportation, the Environmental Protection Agency, and the Occupational Safety and Health Administration.

The GHS itself is not a regulation or a standard. The GHS Document establishes agreed upon hazard classification and communication provisions with explanatory information on how to apply the system. The elements in the GHS supply a mechanism to meet the basic requirement of any hazard communication system, which is to decide if the chemical product produced and/or supplied is hazardous and to prepare a label and/or Safety Data Sheet as appropriate.

Regulatory authorities in countries adopting the GHS will thus take the agreed criteria and provisions, and implement them through their own regulatory process and procedures rather than simply incorporating the text of the GHS into their national requirements.

The GHS Document thus provides countries with the regulatory building blocks to develop or modify existing national programs that address classification of hazards and transmittal of information about those hazards and associated protective measures.

This helps to ensure the safe use of chemicals as they move through the product life cycle from "cradle to grave."

Implementation and Training requirements

You, as an employee, are probably attending this training because your employer is required to communicate hazard information to you in order to comply with OSHA Hazard Communication regulations. OSHA has mandated that all employees must receive training on the new Globally Harmonized System (GHS) by December 1, 2013. This is because you are likely to begin seeing chemical products in the marketplace that comply with this new standard.

If you do not understand what the chemical labels and/or the Safety Data Sheets (SDS) - [which are going to be replacing Material Safety Data Sheets (MSDS)] - are indicating to you, you need to discuss the situation with your supervisor.

The Hazard Communication Standard in 1983 gave the workers the 'right to know', but the new Globally Harmonized System gives workers the ‘right to understand'.

This Fact sheet (http://www.osha.gov/dsg/hazcom/HCSFactsheet.html) discussed OSHA's implementation plan. New changes to the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard are bringing the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), further improving safety and health protections for America's workers.

Building on the success of OSHA's current Hazard Communication Standard, the GHS is expected to prevent injuries and illnesses, save lives and improve trade conditions for chemical manufacturers.

The new hazard communication standard still requires chemical manufacturers and importers to evaluate the chemicals they produce or import and provide hazard information to employers and workers by putting labels on containers and preparing safety data sheets.

However, the old standard allowed chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets - everything you'll need to know will be presented to you in the same manner on labels and in the same locations on safety data sheets.

Benefits: The new standard covers over 43 million workers who produce or handle hazardous chemicals in more than five million workplaces across the country. The modification is expected to prevent over 500 workplace injuries and illnesses and 43 fatalities annually. Once fully implemented it will also:

Enhance worker comprehension of hazards, especially for low and limited-literacy workers, reduce confusion in the workplace, facilitate safety training, and result in safer handling and use of chemicals;
Provide workers quicker and more efficient access to information on the safety data sheets;
Result in cost savings to American businesses of more than $475 million in productivity improvements, fewer safety data sheet and label updates and simpler new hazard communication training; and
Reduce trade barriers by harmonizing with systems around the world.

These are the MAJOR changes to the Hazard Communication Standard:

Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

What will need to done and when:

Chemical users: Continue to update safety data sheets when new ones become available, provide training on the new label elements and update hazard communication programs if new hazards are identified.

Chemical Producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.

Effective Completion Date	Requirement(s)	Who
December 1, 2013	Train employees on the new label elements and SDS format.	Employers
June 1, 2015 *See below December 1, 2015	Comply with all modified provisions of this final rule, except: Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.	Chemical manufacturers, importers, distributors and employers
June 1, 2016	Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.	Employers
Transition Period	Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both.	All chemical manufacturers, importers, distributors and employers

* This date coincides with the European Union implementation date for classification of mixtures.

The Department of Transportation (DOT), Environmental Protection Agency, and the Consumer Product Safety Commission actively participated in developing the GHS. DOT has already modified its requirements for classification and labeling to make them consistent with United Nations transport requirements and the new globally harmonized system.

Global implementation: The new system is being implemented throughout the world by countries including Canada, the European Union, China, Australia, and Japan.

Additional information: More information on the hazard communication standard, including the link to the Federal Register notice, can be found on OSHA's hazard communication safety and health topics page at www.osha.gov/dsg/hazcom/index.html.

Q. Why must training be conducted prior to the compliance effective date?

A. OSHA is requiring that employees are trained on the new label elements (i.e., pictograms, hazard statements, precautionary statements, and signal words) and SDS format by December 1, 2013, while full compliance with the final rule will begin in 2015. OSHA believes that American workplaces will soon begin to receive labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs. It is important to ensure that when employees begin to see the new labels and SDSs in their workplaces, they will be familiar with them, understand how to use them, and access the information effectively.

What are the GHS label elements?

Some GHS label elements have been standardized (identical with no variation) and are directly related to the endpoints and hazard level. Other label elements are harmonized with common definitions and/or principles. See Figure 4.8 (below) for an illustration of the GHS label elements. This "QuickCard" is available at http://www.osha.gov./Publications/HazComm_QuickCard_Labels.html.

oshalabelquickcard

The standardized label elements included in the GHS are:

Symbols (hazard pictograms): Convey health, physical and environmental hazard information, assigned to a GHS hazard class and category.
Signal Words: "Danger" or "Warning" are used to emphasize hazards and indicate the relative level of severity of the hazard, assigned to a GHS hazard class and category.
Hazard Statements: Standard phrases assigned to a hazard class and category that describe the nature of the hazard. The symbols, signal words, and hazard statements have all been standardized and assigned to specific hazard categories and classes, as appropriate.

This approach makes it easier for countries to implement the system and should make it easier for companies to comply with regulations based on the GHS. The prescribed symbols, signal words, and hazard statements can be readily selected from Annex 1 of the "GHS Purple Book" (The actual regulations). These standardized elements are not subject to variation, and should appear on the GHS label as indicated in the GHS for each hazard category/class in the system.

The use of symbols, signal words or hazard statements other than those that have been assigned to each of the GHS hazards would be contrary to harmonization. This means you should NOT see any symbols, signal words or hazard statements - except for the approved ones.

Symbols/Pictograms
The GHS symbols have been incorporated into pictograms for use on the GHS label. Pictograms (Table 4.9) include the harmonized hazard symbols plus other graphic elements, such as borders, background patterns or colors which are intended to convey specific information.

For other sectors, such as transportation, pictograms will have a black symbol on a white background with a red diamond frame (see below). A black frame may be used for shipments within one country. Where a transport pictogram appears, the GHS pictogram for the same hazard should not appear.

Table 4.9

GHS Pictograms and Hazard Classes

Oxidizers	Flammables Self Reactives Pyrophorics Self-Heating Emits Flammable Gas Organic Peroxides	Explosives Self Reactives Organic Peroxides

Acute toxicity (severe)	Corrosives	Gases Under Pressure

Carcinogen Respiratory Sensitizer Reproductive Toxicity Target Organ Toxicity Mutagenicity Aspiration Toxicity	Environmental Toxicity	Irritant Dermal Sensitizer Acute toxicity (harmful) Narcotic Effects Respiratory Tract Irritation

As you can see, these symbols consolidate several different kinds of hazards into a single representation. For example, this symbol

Pictogram

can indicate the product is a carcinogen; or a respiratory sensitizer; or has reproductive or specific "target organ" toxicity; mutagenicity or aspiration toxicity. This symbol could mean one, two or all of these TYPES of hazards. You should take time to become familar with these symbols.

For transport, pictograms will have the background, symbol and colors currently used in the UN Recommendations on the Transport of Dangerous Goods, Model Regulations shown in Table 4.10.

Table 4.10

Transport "Pictograms"

Flammable Liquid Flammable Gas Flammable Aerosol	Flammable solid Self-Reactive Substances	Pyrophorics (Spontaneously Combustible) Self-Heating Substances

Substances, which in contact with water, emit flammable gases (Dangerous When Wet)	Oxidizing Gases Oxidizing Liquids Oxidizing Solids	Explosive Divisions 1.1, 1.2, 1.3

Explosive Division 1.4	Explosive Division 1.5	Explosive Division 1.6

Compressed Gases	Acute Toxicity (Poison): Oral, Dermal, Inhalation	Corrosive

Marine Pollutant	Organic Peroxides

You should only see the transportation symbols on the outside of cases or cartons of products - you will NOT see them on any of the products themselves UNLESS THE PRODUCT SHIPS IN AN ACCEPTED CONTAINER (such as a 55 gallon drum or gas cylinder). It is still a good idea to be familiar with these symbols.

Signal Words
The signal word will indicate the relative degree of severity a hazard. The signal words used in the GHS are:

"Danger" for the more severe hazards, and
"Warning" for the less severe hazards.

NOTE: THERE IS NO �CAUTION� CATEGORY -

Signal words are standardized and assigned to the hazard categories within endpoints. Some products with lower level hazard categories WILL NOT HAVE signal words. The label will carry the signal word corresponding to the most severe hazard class of the product.

Hazard Statements
Hazard statements are standardized and assigned phrases that describe the hazard(s) as determined by hazard classification. An appropriate statement for each GHS hazard should be included on the label for products possessing more than one hazard. This means that a product "could" have several hazard statements - so read the ENTIRE label.

The assigned label elements are provided in each hazard chapter as well as in the Annexes 1 & 2 of the GHS Purple Book. Figure 4-11 illustrates the assignment of standardized GHS label elements for the acute oral toxicity categories.

Figure 4.11

ACUTE ORAL TOXICITY - Annex 1
	Category 1	Category 2	Category 3	Category 4	Category 5
LD50	£ 5 mg/kg	> 5 < 50 mg/kg	³ 50 < 300 mg/kg	³ 300 < 2000 mg/kg	³ 2000 < 5000 mg/kg
Pictogram					No symbol
Signal word	Danger	Danger	Danger	Warning	Warning
Hazard statement	Fatal if swallowed	Fatal if swallowed	Toxic if swallowed	Harmful if swallowed	May be harmful if swallowed

Other GHS label elements include:

Precautionary Statements and Pictograms: Measures to minimize or prevent adverse effects.

Precautionary information supplements the hazard information by briefly providing measures to be taken to minimize or prevent adverse effects from physical, health or environmental hazards. First aid is included in precautionary information. The GHS label should include appropriate precautionary information. Annex 3 of the GHS Purple Book includes precautionary statements and pictograms that can be used on labels.

Annex 3 also includes four types of precautionary statements covering: 1) prevention; 2) response in cases of accidental spillage or exposure; 3) storage; and 4) disposal. The precautionary statements have been linked to each GHS hazard statement and type of hazard. The goal is to promote consistent use of precautionary statements. Annex 3 is guidance and is expected to be further refined and developed over time.

Product Identifier (ingredient disclosure): Name or number used for a hazardous product on a label or in the SDS.

A product identifier should be used on a GHS label and it should match the product identifier used on the SDS. Where a substance or mixture is covered by the UN Model Regulations on the Transport of Dangerous Goods, the UN proper shipping name should also be used on the package.

The GHS label for a substance should include the chemical identity of the substance (name as determined by IUPAC, ISO, CAS or technical name). For mixtures/alloys, the label should include the chemical identities of all ingredients that contribute to ALL GHS hazards, such as, acute toxicity, skin corrosion or serious eye damage, germ cell mutagenicity, carcinogenicity, reproductive toxicity, skin or respiratory sensitization, or Target Organ Systemic Toxicity (TOST), when these hazards appear on the label.

Where a product is supplied exclusively for workplace use, the Competent Authority may give suppliers discretion to include chemical identities on the SDS, in lieu of including them on labels. The Competent Authority rules for confidential business information (CBI) take priority over the rules for product identification.

Supplier identification: The name, address and telephone number should be provided on the label.

The name, address and telephone number of the manufacturer or supplier of the product should be provided on the label.

Supplemental information: non-harmonized information. This can be ANY information that the manufacturer might want to "volunteer" - it is NOT required by regulations.

Supplemental label information is non-harmonized information on the container of a hazardous product that is not required or specified under the GHS.

In some cases this information may be required by a Competent Authority or it may be additional information provided at the discretion of the manufacturer/distributor.

The GHS provides guidance to ensure that supplemental information does not lead to wide variation in information or undermine the GHS information.

Supplemental information may be used to provide further detail that does not contradict or cast doubt on the validity of the standardized hazard information. It also may be used to provide information about hazards not yet incorporated into the GHS.

The labeler should have the option of providing supplementary information related to the hazard, such as physical state or route of exposure, with the hazard statement.

How are multiple hazards handled on labels?
Where a substance or mixture presents more than one GHS hazard, there is a GHS precedence scheme for pictograms and signal words. For substances and mixtures covered by the UN Recommendations on the Transport of Dangerous Goods, Model Regulations, the precedence of symbols for physical hazards should follow the rules of the UN Model Regulations.

For health hazards the following principles of precedence apply for symbols:

(a) if the skull and crossbones applies, the exclamation mark should not appear;

(b) if the corrosive symbol applies, the exclamation mark should not appear where it is used for skin or eye irritation;

(c) if the health hazard symbol appears for respiratory sensitization, the exclamation mark should not appear where it is used for skin sensitization or for skin or eye irritation.

For signal words:

(a) If the signal word 'Danger' applies, the signal word 'Warning' should not appear.

For hazard statements:

(a) All assigned hazard statements should appear on the label. The Competent Authority may choose to specify the order in which they appear.

Is there a specific GHS label format / layout?
The GHS hazard pictograms, signal word and hazard statements should be located together on the label. The actual label format or layout is not specified in the GHS. National authorities may choose to specify where information should appear on the label or allow supplier discretion.

Figure 4.12 shows an example of a GHS label for the fictional product 'ToxiFlam'. The core GHS label elements are expected to replace the need for the array of different labels.

Figure 4.12 Example GHS Inner Container Label (e.g., bottle inside a shipping box)

ToxiFlam (Contains: XYZ)

Danger! Toxic If Swallowed, Flammable Liquid and Vapor

Do not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container tightly closed. Keep away from heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof electrical equipment. Take precautionary measures against static discharge.
Use only non-sparking tools. Store in cool/well-ventilated place.

IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician. Rinse mouth.

In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam.
See Material Safety Data Sheet for further details regarding safe use of this product.

MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999

There has been discussion about the size of GHS pictograms and that a GHS pictogram might be confused with a transport pictogram or "diamond". Transport pictograms are different in appearance than the GHS pictograms.

The Purple Book explains how the GHS pictograms are expected to be proportional to the size of the label text. So that generally the GHS pictograms would be smaller than the transport pictograms.

Several arrangements for GHS labels are also provided in Annex 7 of the Purple Book. Figure 4.13 shows an arrangement for a combination packaging with an outer shipping box and inner bottles. The shipping box has a transportation pictogram. The inner bottles have a GHS label with a GHS pictogram.

Figure 4.13 Combination Packaging (Outer transport box with inner bottles)

For a container such as a 55 gallon drum, the transport required markings and pictograms may be combined with the GHS label elements or presented separately. In Figure 4.14 a label arrangement for a single packaging such as a 55 gallon drum is shown. Pictograms and markings required by the transport regulations as well as GHS label and non-duplicative GHS pictogram are shown on the drum.

Figure 4.14 Combination Packaging (Container is transport package)

A label merging the transportation requirements and the GHS requirements into one label for the fictional product "ToxiFlam" is shown in Figure 4.15. This combined type label could be used on a 55 gallon drum, for example.

Figure 4.15 Example GHS Outer Container Label (55 gallon/200 liter drum)

ToxiFlam	Flammable liquids, toxic, n.o.s.
Danger! Toxic If Swallowed Flammable Liquid and Vapor	(contains XYZ) UN 1992
Do not eat, drink or use tobacco when using this product. Wash hands thoroughly after handling. Keep container tightly closed. Keep away from heat/sparks/open flame. - No smoking. Wear protective gloves and eye/face protection. Ground container and receiving equipment. Use explosion-proof electrical equipment. Take precautionary measures against static discharge. Use only non-sparking tools. Store in cool/well-ventilated place IF SWALLOWED: Immediately call a POISON CONTROL CENTER or doctor/physician. Rinse mouth. In case of fire, use water fog, dry chemical, CO2, or "alcohol" foam. See Material Safety Data Sheet for further details regarding safe use of this product.

MyCompany, MyStreet, MyTown NJ 00000, Tel: 444 999 9999

Are workplace containers covered in the GHS ?
Products falling within the scope of the GHS will carry the GHS label at the point where they are supplied to the workplace by a manufacturer or distributor, and that label should be maintained on the supplied container in the workplace.

The GHS label or label elements can also be used for workplace containers (e.g., storage tanks). However, the Competent Authority can allow employers to use alternative means of giving workers the same information in a different written or displayed format when such a format is more appropriate to the workplace and communicates the information as effectively as the GHS label.

For example, label information could be displayed in the work area on a large poster in proximity to the product, rather than on the individual containers. Some examples of workplace situations where chemicals may be transferred from supplier containers include: containers for laboratory testing, storage vessels, piping or process reaction systems or temporary containers where the chemical will be used by one worker within a short timeframe.

What is the GHS Safety Data Sheet (SDS)?
The GHS Safety Data Sheet (SDS) will replace the current "material safety data sheet" (MSDS) and will provide comprehensive information for use in workplace chemical management. Employers and workers will use the SDS as sources of information about hazards and to obtain advice on safety precautions.

The SDS is product related and, usually, is not able to provide information that is specific for any given workplace where the product may be used. However, the SDS information enables the employer to develop an active program of worker protection measures, including training, which is specific to the individual workplace and to consider any measures that may be necessary to protect the environment.

Information in a SDS also provides a source of information for other target audiences such as those involved with the transport of dangerous goods, emergency responders, poison centers, those involved with the professional use of pesticides and consumers. This OSHA QuickCard is available at: http://www.osha.gov/Publications/OSHA3493QuickCardSafetyDataSheet.pdf.

sds_fact_sheet

The SDS should contain 16 headings (Figure 4.14). The GHS MSDS headings, sequence and content are similar to the ISO, EU and ANSI MSDS/SDS requirements, except that the order of sections 2 and 3 have been reversed.

The SDS should provide a clear description of the data used to identify the hazards. Figure 4.14 and the GHS Purple Book provide the minimum information that is required in each section of the SDS. An example of a draft GHS SDS is provided below. The guidance document provides examples in Appendix B.

Figure 4.14
Minimum information for an SDS

1.	Identification of the substance or mixture and of the supplier	GHS product identifier. Other means of identification. Recommended use of the chemical and restrictions on use. Supplier's details (including name, address, phone number, etc.). Emergency phone number.
2.	Hazards identification	GHS classification of the substance/mixture and any national or regional information. GHS label elements, including precautionary statements. (Hazard symbols may be provided as a graphical reproduction of the symbols in black and white or the name of the symbol, e.g., flame, skull and crossbones.) Other hazards which do not result in classification (e.g., dust explosion hazard) or are not covered by the GHS.
3.	Composition/information on ingredients	Substance Chemical identity. Common name, synonyms, etc. CAS number, EC number, etc. Impurities and stabilizing additives which are themselves classified and which contribute to the classification of the substance. Mixture The chemical identity and concentration or concentration ranges of all ingredients which are hazardous within the meaning of the GHS and are present above their cutoff levels. *NOTE*: For information on ingredients, the competent authority rules for CBI take priority over the rules for product identification.
4.	First aid measures	Description of necessary measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact, and ingestion. Most important symptoms/effects, acute and delayed. Indication of immediate medical attention and special treatment needed, if necessary.
5.	Firefighting measures	Suitable (and unsuitable) extinguishing media. Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products). Special protective equipment and precautions for firefighters.
6.	Accidental release measures	Personal precautions, protective equipment and emergency procedures. Environmental precautions. Methods and materials for containment and cleaning up.
7.	Handling and storage	Precautions for safe handling. Conditions for safe storage, including any incompatibilities.
8.	Exposure controls/personal protection.	Control parameters, e.g., occupational exposure limit values or biological limit values. Appropriate engineering controls. Individual protection measures, such as personal protective equipment.
9.	Physical and chemical properties	Appearance (physical state, color, etc.). Odor. Odor threshold. pH. melting point/freezing point. initial boiling point and boiling range. flash point. evaporation rate. flammability (solid, gas). upper/lower flammability or explosive limits. vapor pressure. vapor density. relative density. solubility(ies). partition coefficient: n-octanol/water. autoignition temperature. decomposition temperature.
10.	Stability and reactivity	Chemical stability. Possibility of hazardous reactions. Conditions to avoid (e.g., static discharge, shock or vibration). Incompatible materials. Hazardous decomposition products.
11.	Toxicological information	Concise but complete and comprehensible description of the various toxicological (health) effects and the available data used to identify those effects, including: information on the likely routes of exposure (inhalation, ingestion, skin and eye contact); Symptoms related to the physical, chemical and toxicological characteristics; Delayed and immediate effects and also chronic effects from short- and long-term exposure; Numerical measures of toxicity (such as acute toxicity estimates).
12.	Ecological information	Ecotoxicity (aquatic and terrestrial, where available). Persistence and degradability. Bioaccumulative potential. Mobility in soil. Other adverse effects.
13.	Disposal considerations	Description of waste residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging.
14.	Transport information	UN Number. UN Proper shipping name. Transport Hazard class(es). Packing group, if applicable. Marine pollutant (Yes/No). Special precautions which a user needs to be aware of or needs to comply with in connection with transport or conveyance either within or outside their premises.
15.	Regulatory information	Safety, health and environmental regulations specific for the product in question.
16.	Other information including information on preparation and revision of the SDS

Q. How is the Safety Data Sheet (SDS) changing under the revised Hazard Communication Standard?

A. The information required on the safety data sheet (SDS) will remain essentially the same as that in the current standard. The current/former Hazard Communication Standard (HCS) indicated what information has to be included on an SDS but did not specify a format for presentation or order of information. The new/revised HCS requires that the information on the SDS be presented using consistent headings in a specified sequence.

Paragraph (g) of the final rule indicates the headings of information to be included on the SDS and the order in which they are to be provided. In addition, Appendix D indicates what information is to be included under each heading. The SDS format is the same as the ANSI standard format which is widely used in the U.S. and is already familiar to many employees.

The format of the 16-section SDS should include the following sections:

Section 1. Identification

Section 2. Hazard(s) identification

Section 3. Composition/information on ingredients

Section 4. First-Aid measures

Section 5. Fire-fighting measures

Section 6. Accidental release measures

Section 7. Handling and storage

Section 8. Exposure controls/personal protection

Section 9. Physical and chemical properties

Section 10. Stability and reactivity

Section 11. Toxicological information

Section 12. Ecological information

Section 13. Disposal considerations

Section 14. Transport information

Section 15. Regulatory information

Section 16. Other information, including date of preparation or last revision

Sections 12-15 is considered "supplemental information" and may be included in the SDS, but are not required by OSHA.

DETAILED DISCUSSION of differences ---
What is the difference between the GHS SDS and existing MSDSs/SDSs?

SDSs are in use globally. So it is useful to have an understanding of the similarities and differences in the existing MSDS/SDS content and format and the GHS SDS content and format. A table comparing MSDS/SDS content/format is provided below.

Comparison of MSDS/SDS Elements

The following tables provide a comparison of MSDS elements for the following:

Globally Harmonized System
1 ISO Safety Data Sheet for Chemical Products 11014-1: 2003 DRAFT
2 ANSI MSDS Preparation Z400.1- 2004
3 OSHA Hazard Communication Standard 29#CFR#1910.12004

*1. Globally Harmonized System of Classification and Labeling of Chemicals (GHS), United Nations, 2005.
*2. ISO 11014-1:2003 DRAFT Safety Data Sheet for Chemical Products.
*3. American National Standard for Hazardous Industrial Chemicals-MSDS Preparation (ANSI Z-400.1-2004).
*4. U.S. DOL, OSHA, 29 CFR 1910.1200, HAZCOM.

So, we can now review a fictional product SDS to get a "feel" for how the new Safety Data Sheets (replacing the MSDS) will appear.

Example SDS for fictional product

Bondit
(GHS MSDS Example)

1. Identification

Name of the product: Bondit
Recommended use: General adhesive.
Producer:
GHS Ltd., UK -
London, SE, Southwarkbridge 1

Telephone no. +44 171717 555.555 5,
Emergency no. +44 171717 333 333 3

2. Hazard(s) identification

Classification:
Flammable liquid, Category 2
Eye irritation, Category 2A
Hazardous to the aquatic environment, Acute Category 3

Labeling:

Symbol: Flame, Exclamation mark
Signal word:Danger
Hazard statement:
Highly flammable liquid and vapor.
Causes severe eye irritation.
Harmful to aquatic life.
Precautionary statements:
Keep container tightly closed.
Keep away from heat/sparks/open flame. - No smoking.
Wear protective gloves and eye/face protection.
Ground/Bond container and receiving equipment.
Use explosion-proof electrical/ventilating/lighting/ equipment.
Take precautionary measures against static discharge.
Use only non-sparking tools.
Store in cool/well-ventilated place.
Avoid release to the environment.

3. Composition / Information on ingredients

Chemical identity: Component A 70-80%
Common name: Solvent A
Numbers of identity: CAS-Nr.:111111-11-1
Impurities: None

Chemical identity: Component C 20-25%
Common name: Not applicable
Numbers of identity: CAS-Nr.: 44444-44-4
Impurities: none

4. First-aid measures

Inhalation:
Remove person to fresh air. If respiratory irritation, dizziness, nausea, or unconsciousness occurs, seek immediate medical assistance. If breathing has stopped, give artificial respiration.

Skin contact:
Wash the contaminated area with soap and water. Remove contaminated clothing and wash before reuse. If irritation develops, get medical attention.

Eye contact:
Hold eyelids apart and flush eyes with plenty of water for at least 15 minutes. Get medical attention.

Ingestion:
If swallowed, do NOT induce vomiting. Seek immediate medical attention.

5. Firefighting measures

Suitable extinguishing media: Foam, extinguishing powder, carbon dioxide, water fog. In case of fire, cool endangered containers with water fog.

Unsuitable extinguishing media: High pressure water jet.

Specific hazards in case of fire: None are known.

Special protective equipment and precaution for fire fighters: For fires in enclosed areas, wear self-contained breathing apparatus. Do not inhale combustion gases.

6. Accidental release measures

Personal precautions:
Depending on extent of release, consider the need for fire fighters/emergency responders with adequate personal protective equipment for cleaning up.

Do not eat, drink or smoke while cleaning up. Use a self-contained respirator, a mask with filter (type A class 3) or a filtering mask (e.g., EN 405). Wear protective clothing, safety glasses and impervious gloves (e.g., neoprene gloves). Ensure adequate ventilation. Avoid all sources of ignition, hot surfaces and open flames (see also Section 7).

Environmental precautions:
Prevent spills from entering storm sewers or drains and contact with soil.

Methods and materials for containment and cleaning up:
Eliminate all ignition sources. Runoff may create fire or explosion hazard in sewer system. Absorb on fire retardant, liquid-absorbing material (treated sawdust, diatomaceous earth, sand). Shovel up and dispose of at an appropriate waste disposal facility in accordance with current applicable laws and regulations, and product characteristics at time of disposal (see also Section 13).

7. Handling and storage

Precautions for safe handling:
Avoid contact with eyes. Avoid prolonged repeated skin contact and breathing mists/vapors.

Use in well-ventilated area away from all ignition sources. Switch off all electrical devices such as parabolic heaters, hotplates, storage heaters etc. in good time for them to have cooled down before commencing work. Do not smoke; do not weld. Do not empty waste into sanitary drains. Take measures to prevent the build up of electrostatic charge.

Conditions for safe storage, including incompatibilities:
Storage containers must be grounded and bonded. Store away from all ignition sources in a cool area equipped with an automatic sprinkling system. Ensure adequate ventilation. Store at temperatures between +5 and +50°C. Store only in the original container.

8. Exposure controls / personal protection

Information on the system design:
Draw off vapors directly at the point of generation and exhaust from the work area. In the case of regular work, provide bench-mounted extraction equipment.

Exposure Limits:

Component Name (CAS-No.)	Reference	TWA		STEL
	Reference	ppm	mg/m3	ppm	mg/m3
	UK OEL	500	1200	--	--
Component C (4444-44-4)	German MAK	200	950	--	--

Ventilation:
Use in well-ventilated area with local exhaust.

Respiratory protection:
Approved respiratory equipment must be used when airborne concentrations are unknown or exceed the exposure limits. When processing large amounts, use a light duty construction compressed air line breathing apparatus (e.g., in accordance with EN1835), a mask with filter (type A class 3, color brown) or a filtering half mask (e.g., in accordance with EN 405) when there is inadequate ventilation.

Eye protection:
Safety glasses with side shields or chemical goggles must be worn.

Skin protection:
If prolonged or repeated skin contact is likely, neoprene gloves should be worn. Good personal hygiene practices should always be followed.

9. Physical and chemical properties

Physical state: Liquid
Color: Colorless, transparent
Odor: Solvent, ester-like
Odor threshold: Not available
pH-value: Not applicable
Melting point: Not available
Freezing Point: Not available
Initial boiling point: 56°C
Flash point: - 22°C DIN 51755
Evaporation rate: Not available
Flammability (solid, gas): Not applicable
Explosion limits: lower limit = 1.4 Vol%; upper limit 13.0 Vol% (literature)
Vapor pressure: 240 mbar (highest partial vapor pressure) at 20°C
Vapor density: Not available
Relative density: 0.89 g/cm3 at 20°C
Solubility: Partially soluble in water at 20°C
Partition coefficient: Log Kow = 3.3
Auto-ignition temperature: Not available
Decomposition temperature: Not available

10. Stability and reactivity

Chemical stability: No decomposition, if used according to specifications.
Possibility of hazardous reactions: None are known.
Conditions to avoid: Heat, sparks, flame and build up of static electricity.
Materials to avoid: Halogens, strong acids, alkalies and ozidizers.
Hazardous decomposition products: None are known.

11. Toxicological information

Acute Toxicity:

Test	Results	Basis
Oral Toxicity (Rats)	Not Classified	Based on Ingredients
Dermal Toxicity (Rats)	Not Classified	Product Test Data
Inhalation Toxicity, Vapor (Rats)	Not Classified	Based on Testing of Similar Materials
Eye Irritation (Rabbits)	Eye Irritant Category 2A	Based on Testing of Similar Materials
Dermal Irritation (Rabbits)	Not Classified	Product Test Data

Summary Comments: May cause severe eye irritation like ocular lesions, which are reversible.

Subchronic/Chronic Toxicity:

Test	Results	Comments
Dermal Sensitization (Guinea Pig)	Not Classified: Negative response in Bueller, guinea pig test. 0% animals considered positive.	Product Test Data

Summary Comments: Component A may have a drying effect on the skin; frequent or prolonged contact may cause flaking or cracking of the skin.

12. Ecological information

Persistence and degradability: The total of the organic components contained in the product is not classified as "readily biodegradable" (OECD-301 A-F). However, this product is expected to be inherently biodegradable.

Bio-accumulative potential: There is no evidence to suggest bioaccumulation will occur.

Mobility: Accidental spillage may lead to penetration in the soil and groundwater. However, there is no evidence that this would cause adverse ecological effects.

Aquatic Toxicity:

Test	Results	Comments
Acute Toxicity	Acute Category 3: 96 hr. LC50 = 65 mg/L	Product Test Data

13. Disposal considerations

Waste Disposal:
Product is suitable for burning in an enclosed, controlled burner for fuel value or disposal by supervised incineration. Such burning may be limited by local regulation. The product is suitable for processing at an appropriate government waste disposal facility. Use of these methods is subject to user compliance with applicable laws and regulations and consideration of product characteristics at time of disposal.

Recommended European waste code (EWC): 080406

14. Transport information

UN-number: 1993
UN proper shipping name: Flammable Liquid, N.O.S. (Contains Component C)
Transport hazard class: 3
Packing group: II
Marine Pollutant: No

15. Regulatory information

Inventory Status:
All components are on TSCA, EINECS/ELINCS, AICS, and DSL.

German:
Regulations governing combustible liquids (German-VbF) class: AI

German water endangering class (WGK) = 1, slightly water-endangering product (manufacturer classification.)

Australian Regulations:

AS 1940 Class: PGII
Poisons Schedule: S5

U.S. Regulations:

U.S. Superfund Amendments and Reauthorization Act (SARA) Title III:

SARA (311/312) HAZARD CATEGORIES:
FIRE, ACUTE

SARA 313: This product contains the following SARA 313 Toxic Release Chemicals.

Chemical Name	CAS Number	Concentration
Component A	111111-11-1	70-80%
Component C	4444-44-4	20-25%

The following product components are cited on the lists below:

Chemical Name	CAS Number	List Citations
Component A	111111-11-1	NJ RTK, TSCA 12(b)
Component C	4444-44-4	Prop. 65, NJ RTK

16. Other information

Abbreviations and acronyms:
UK OES = United Kingdom Occupational Exposure Standards
German MAK = Germany Maximum Allowable Concentration

MSDS Preparation date: July 1, 2005

The information contained herein is accurate to the best of our knowledge. My Company makes no warranty of any kind, express or implied, concerning the safe use of this material in your process or in combination with other substances.

In reality, there is not much difference. The product still lists the warnings and precautions prominently, so that workers will know what effects the products might have and what safety equipment is needed to properly protect themselves and use the materials.

Your employer is required to have a “hazmat” communication plan in place to comply with OSHA regulations.

The basic goal of an effective hazard communication program is to ensure employers and employees know the identities and hazards of chemicals in their workplaces. When employers and employees have such information, it can be used to design and implement appropriate protective measures to reduce the incidence of adverse effects.

OSHA's Hazard Communication Standard (HCS) is designed to ensure that information about these hazards and associated protective measures is disseminated.

This is accomplished by requiring chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import, and to provide information about them through labels on shipped containers and more detailed information sheets called safety data sheets (SDSs).

All employers with hazardous chemicals in their workplaces must prepare and implement a written hazard communication program, and must ensure that all containers are labeled, employees are provided access to SDSs, and an effective training program is conducted for all potentially exposed employees.

The employees need to provide their full attention during these training sessions so you understand your employers' protective programs and take steps to protect themselves.

Your job duties might include participating in the program. Your responsibilities might be to review and update the SDS for the products that you handle and report the change to your employer or to hold additional training classes to inform your co-workers.

REVIEW QUESTIONS

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Question 1 - The GHS is an acronym for The Globally Harmonized System. The GHS is a system was designed for standardizing and harmonizing the classification and labeling of chemicals - worldwide.

		1. True
Answer 1		2. False

Question 2 - Your employer is required to communicate hazard information to you in order to comply with OSHA Hazard Communication regulations.

		1. True
Answer 2		2. False

Question 3 - OSHA has mandated that all employees must receive training on the new Globally Harmonized System (GHS) by December 1, 2013. This is because you are likely to begin seeing chemical products in the marketplace that comply with this new standard.

		1. True
Answer 3		2. False

Question 4 - The Hazard Communication Standard in 1983 gave the workers the 'right to know', but the new Globally Harmonized System gives workers the ‘right to understand'.

		1. True
Answer 4		2. False

Question 5 - The old standard allowed chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose. The modified standard provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets.

		1. True
Answer 5		2. False

Question 6 - OSHA is requiring that employees are trained on the new label elements (i.e., pictograms, hazard statements, precautionary statements, and signal words) and SDS format by December 1, 2013, while full compliance with the final rule will begin in 2015. OSHA believes that American workplaces will soon begin to receive labels and SDSs that are consistent with the GHS, since many American and foreign chemical manufacturers have already begun to produce HazCom 2012/GHS-compliant labels and SDSs.

		1. True
Answer 6		2. False

Question 7 - This symbol Pictogram will mean:

		1. Acute toxicity (severe)
Answer 7		2. Corrosive

Question 8 - This symbol Pictogram will mean:

		1. Corrosive
Answer 8		2. Flammable

Question 9 - The GHS is an acronym for the "Globally Harmonized System" of Classification and Labeling of Chemicals.

		1. True
Answer 9		2. False

Question 10 - The GHS is a system for standardizing and harmonizing the classification and labeling of chemicals - worldwide.

		1. True
Answer 10		2. False

Question 11 - This is a transportation symbol Pictogram ALL GHS hazard symbols will be in a "red" diamond.

		1. True
Answer 11		2. False

Question 12 - In the past, Chemical manufacturers and importers to convey hazard information on labels and material safety data sheets in whatever format they chose.

		1. True
Answer 12		2. False

Question 13 - The new regulations will provide a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets.

		1. True
Answer 13		2. False

Question 14 - A major change - Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.

		1. True
Answer 14		2. False

Question 15 - A major change - Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.

		1. True
Answer 15		2. False

Question 16 - A major change - Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.

		1. True
Answer 16		2. False

Question 17 - A major change - Information and training: To facilitate understanding of the new system, the new standard requires that workers must be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

		1. True
Answer 17		2. False

Question 18 - Employers must provide training on the new system by December 1, 2013, even though chemical manufacturers and importers have until June 1, 2012 to comply (and distributors can still ship "old" product until December 1, 2015).

		1. True
Answer 18		2. False

Question 19 - GHS training is required because products with the new labeling system might begin showing up in the marketplace at anytime - as this is a global system.

		1. True
Answer 19		2. False

Question 20 - All employers with hazardous chemicals in their workplaces must prepare and implement a written hazard communication program, and must ensure that all containers are labeled; that employees are provided access to MSDSs; and an effective training program is conducted for all potentially exposed employees.

		1. True
Answer 20		2. False

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MSDS Comparison
MSDS Sections	*GHS SDS 1**	*ISO MSDS 2**	*ANSI MSDS 3**	*OSHA MSDS 4**
1. Product and company identification	GHS product identifier. Other means of identification. Recommended use of the chemical and restrictions on use. Supplier's details (including name, address, phone number etc). Emergency phone number.	GHS product identifier. Other means of identification. Recommended use of the chemical and restrictions on use. Supplier's details (including name, address, phone number etc). Emergency phone number.	Product identity same as on label Product name, product code name, address and telephone number of supplier emergency telephone number	Product identity same as on label. Name address and telephone number of the manufacturer, distributor, employer or other responsible party.
2. Hazards identification	GHS classification of the substance/mixture and any regional information. GHS label elements, including precautionary statements. (Hazard symbols may be provided as a graphical reproduction of the symbols in black and white or the name of the symbol, e.g., flame, skull and crossbones.) Other hazards which do not result in classification(e.g., dust explosion hazard) or are not covered by the GHS.	GHS classification of the substance/mixture and any regional information. GHS label elements, including precautionary statements. (Hazard symbols may be provided as a graphical reproduction of the symbols in black and white or the name of the symbol, e.g., flame, skull and crossbones.) Other hazards which do not result in classification (e.g., dust explosion hazard) or are not covered by the GHS.	Emergency Overview (description of product and most significant immediate physical, health and environmental concerns) OSHA Regulatory Status Potential health effects (information on adverse human health effects and symptoms, relevant route(s) and length of exposure, type and severity of effects, target organs, medical symptoms that are aggravated by exposure) if listed as a carcinogen by OSHA, IARC, NTP environmental effects	health hazards including acute and chronic effects, listing target organs or systems signs & symptoms of exposure conditions generally recognized as aggravated by exposure primary routes of exposure if listed as a carcinogen by OSHA, IARC, NTP physical hazards, including the potential for fire, explosion, and reactivity
3. Composition/ information on ingredients	*Substance* Chemical identity Common name, synonyms, etc. CAS number, EC number, etc. Impurities and stabilizing additives which are themselves classified and which contribute to the classification of the substance. *Mixture* The chemical identity and concentration or concentration ranges of all ingredients which are hazardous within the meaning of the GHS and are present above their cut-off levels. Cut-off level for reproductive toxicity, carcinogenicity and category 1 mutagenicity is ³ 0.1% Cut-off level for all other hazard classes is ³ 1% Note: For information on ingredients, the competent authority rules for CBI take priority over the rules for product identification	*Substance* Chemical identity Common name, synonyms etc. CAS number, EC number, etc. Impurities and stabilizing additives which are themselves classified and which contribute to the classification of the substance. *Mixture* The chemical identity and concentration or concentration ranges of all ingredients which are hazardous within the meaning of the GHS and are present above their cut-off levels. Cut-off level for reproductive toxicity, carcinogenicity and category 1 mutagenicity is ³ 0.1% Cut-off level for all other hazard classes is ³ 1%	common chemical name(s) generic name(s) synonyms CAS number(s) components or impurities contributing to the hazard (name, concentration)	Chemical and common name of ingredients contributing to known hazards For untested mixtures, the chemical & common name of ingredients at 1% or more that present a health hazard and those that present a physical hazard in the mixture Ingredients at 0.1% or greater, if carcinogens
4. First-aid measures	Description of necessary measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact and ingestion. Most important symptoms/effects, acute and delayed. Indication of immediate medical attention and special treatment needed, if necessary.	Description of necessary measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact and ingestion. Most important symptoms/effects, acute and delayed. Indication of immediate medical attention and special treatment needed, if necessary.	first aid procedures by route of exposure, i.e., inhalation, skin contact, eye contact, ingestion important symptoms and effects useful for diagnostic treatment antidotes notes to a physician	emergency & first aid procedures
5. Firefighting measures	Suitable (and unsuitable) extinguishing media. Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products). Special protective equipment and precautions for fire-fighters.	Suitable (and unsuitable) extinguishing media. Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products). Special protective equipment and precautions for firefighters.	Qualitative flammable and reactivity properties suitable extinguishing media unsuitable extinguishing media Guidance to firefighters Specific hazards arising from the chemical Protective equipment and precautions for firefighters	generally applicable control measures flammable property information such as flash point physical hazards including the potential for fire, explosion, and reactivity
6. Accidental release measures	Personal precautions, protective equipment and emergency procedures. Environmental precautions. Methods and materials for containment and cleaning up.	Personal precautions, protective equipment and emergency procedures. Environmental precautions. Methods and materials for containment and cleaning up.	Clean-up technique Personal Precautions Environmental Precautions containment technique regulatory information	procedures for clean up of spills and leaks
7. Handling and storage	Precautions for safe handling. Conditions for safe storage, including any incompatibilities.	Precautions for safe handling. Conditions for safe storage, including any incompatibilities.	handling measures to prevent exposure and release, prevent fire or explosion and ensure precautions for safe handling storage storage conditions and technical measures for safe storage incompatibilities suitable/non suitable packaging material	Precautions for safe handling & use, including appropriate hygenic practices.
8. Exposure controls/personal protection	Control parameters (e.g., occupational exposure limit values or biological limit values). Appropriate engineering controls. Individual protection measures, such as personal protective equipment.	Control parameters (e.g., occupational exposure limit values or biological limit values). Appropriate engineering controls. Individual protection measures, such as personal protective equipment.	exposure guidelines (limit values) engineering controls to minimize hazards personal protective equipment (respiratory, hand, eye, skin and body protection) General Hygiene Considerations	General applicable control measures appropriate engineering controls and work practices protective measures during maintenance & repair personal protective equipment permissible exposure levels, threshold limit values, listed by OSHA, ACGIH, or established company limits.
9. Physical and chemical properties	Appearance (physical state, color, etc.) Odor Odor threshold pH melting point/freezing point initial boiling point and boiling range flash point: evaporation rate flammability (solid, gas) upper/lower flammability or explosive limits vapor pressure vapor density relative density: solubility(ies) partition coefficient: n-octanol/water auto-ignition temperature decomposition temperature	Appearance (physical state, color, etc.) Odor Odor threshold pH melting point/freezing point initial boiling point and boiling range flash point: evaporation rate flammability (solid, gas) upper/lower flammability or explosive limits vapor pressure vapor density relative density: solubility(ies) partition coefficient: n-octanol/water auto-ignition temperature decomposition temperature	appearance (color, physical form, shape) odor/odor threshold physical state pH melting/freezing point(specify which) initial boiling point and boiling range flash point evaporation rate flammability (solid, gas) upper/lower flammability or explosive limits vapor pressure vapor density specific gravity or relative density solubility(ies) (specify solvent, e.g., water) partition coefficient: n-octanol/water auto-ignition temperature decomposition temperature. other relevant data	characteristics of hazardous chemicals such as vapor pressure & density. physical hazards including the potential for fire, explosion, and reactivity.
10. Stability and reactivity	Chemical stability. Possibility of hazardous reactions. Conditions to avoid (e.g., static discharge, shock or vibration). Incompatible materials, Hazardous decomposition products.	Chemical stability. Possibility of hazardous reactions. Conditions to avoid (e.g., static discharge, shock or vibration). Incompatible materials. Hazardous decomposition products.	Physical hazards chemical stability conditions to avoid Incompatible Materials hazardous decomposition products Possibility of Hazardous Reactions	organic peroxides, pyrophoric, unstable # (reactive), or water-reactive hazards physical hazards, including reactivity and hazardous polymerization
11. Toxicological information	Concise but complete and comprehensible description of the various toxicological (health) effects and the available data used to identify those effects, including: Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact); Symptoms related to the physical, chemical and toxicological characteristics; Delayed and immediate effects and also chronic effects from short- and long-term exposure;. Numerical measures of toxicity (such as acute toxicity estimates).	Concise but complete and comprehensible description of the various toxicological (health) effects and the available data used to identify those effects, including: Information on the likely routes of exposure (inhalation, ingestion, skin and eye contact); Symptoms related to the physical, chemical and toxicological characteristics; Delayed and immediate effects and also chronic effects from short- and long-term exposure; Numerical measures of toxicity (such as acute toxicity estimates).	Toxicological information: human, animal, and in vitro data, SAR acute dose effects: single/ short-term exposures. (e.g., LD50, LC50). Repeated dose effects: (e.g., NOAEL) Irritation/Corrosivity Sensitization (skin and respiratory) Carcinogenicity Neurological effects Genetic effects (e.g., mutagenicity) Reproductive effects Developmental effects Target organ effects	See also Section 2 [health hazards Including acute and chronic effects, listing target organs or systems signs & symptoms of exposure primary routes of exposure if listed as a carcinogen by OSHA, IARC, NTP]
12. Ecological information	Ecotoxicity (aquatic and terrestrial, where available). Persistence and degradability Bioaccumulative potential Mobility in soil Other adverse effects	Ecotoxicity (aquatic and terrestrial, where available). Persistence and degradability Bioaccumulative potential Mobility in soil Other adverse effects	ecotoxicity acute and long term (fish, invertebrates) persistence / degradability bioaccumulation / bioconcentration mobility: air, soil, water Other adverse effects	No present requirements.
13. Disposal considerations	Description of waste residues and information on their safe handling and methods of disposal, including any contaminated packaging.	Description of waste residues and information on their safe handling and methods of disposal, including any contaminated packaging.	safe and environmentally preferred waste management of the material and/or its container classification under applicable law	No present requirements, See section 7,
14. Transport information	UN number. UN Proper shipping name. Transport Hazard class(es). Packing group, if applicable. Marine pollutant (Y/N). Special precautions which a user needs to be aware of or needs to comply with in connection with transport or conveyance either within or outside their premises.	UN number. UN Proper shipping name. Transport Hazard class(es). Packing group, if applicable. Marine pollutant (Y/N). Special precautions which a user needs to be aware of or needs to comply with in connection with transport or conveyance either within or outside their premises.	proper shipping name hazard class(es) identification number packing group hazardous substances marine pollutants (Y/N) IMDG classification TDG classification ICAO/IATA classification RID/ADR classification	No present requirements,
15. Regulatory information	Safety, health and environmental regulations specific for the product in question.	Safety, health and environmental regulations specific for the product in question.	U.S. federal regulations international regulations U.S. state regulations	No present requirements.
16. Other information	Other information including information on preparation and revision of the SDS.	Other information including information on preparation and revision of the SDS.	label text hazard rating and rating system information on preparation and revision of safety data sheet Key/legend	Date of preparation of MSDS or date of last change

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Technician Regulation and Safety Training

Label and MSDS Changes GHS - Globally Harmonized System of Classification and Labeling of Chemicals

Implementation and Training requirements

What are the GHS label elements?

Label and MSDS Changes
GHS - Globally Harmonized System of Classification
and Labeling of Chemicals