Office of Environmental Health & Safety (OEHS)
B. SDS Formats
I. The OSHA Hazard Communication (HAZCOM) Standard
The purpose of the OSHA Hazard Communication Standard, 29 CFR 1910.1200, is to ensure that the hazards of chemicals are evaluated, and that information concerning the hazards is transmitted to employers and employees. Many chemicals/products used in the work environment can present inherent physical and/or health hazards. If used properly, exposure can be minimized and the chance of accidents can be reduced. Workers have a "right to know" about the chemical hazards they face on the job and how to protect themselves.
With the establishment of the HAZCOM Standard, OSHA has given employers a clear responsibility to protect their workers from hazardous chemicals. The basic intent of the HAZCOM Standard is the transmittal of INFORMATION - seeing to it that employees understand the risks of the substances they work with and how to protect themselves. This information transmittal is accomplished by means of a comprehensive hazard communication program including inventory lists of hazardous chemicals present, container labeling and other forms of warning, Safety Data Sheets (SDSs), and employee training.
The HAZCOM Standard covers all employers with employees exposed to hazardous chemicals in the workplace. Literally all companies that manufacture, distribute, import, or use hazardous chemicals are required to meet the provisions of the OSHA HAZCOM Standard.
It is interesting to note that in the HAZCOM Standard, the term "employee" is defined as a worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Employees such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered by the Standard. However, Tulane feels that if an office worker or other employee is located near a laboratory or in a department or building where chemicals are routinely used, that office worker/employee needs to be familiar with HAZCOM requirements. An emergency could develop and that office worker/employee, although not using chemicals, could still encounter hazards and should still know the procedures available to protect himself/herself. Therefore, at Tulane, HAZCOM training and information is available to all employees, and due to the quantity and variety of chemicals used at our facilities, all Tulane employees are strongly encouraged to participate.
As a preliminary step in the HAZCOM Standard, chemical manufacturers are required to evaluate the hazards of the substances they produce and determine how those hazards can best be avoided. They then must transmit that information to customers, both on container labels and on a Safety Data Sheet (SDS) for each chemical. Importers and distributors also must send an SDS with each chemical they ship. Customers (like Tulane) are then required to ensure that the information received on the label and on the SDS is made available to those employees who may be affected. Labeling and the SDS play a central role in HAZCOM. Later discussion will emphasize these points.
Employee training is also essential to successful implementation of the HAZCOM Standard. While Tulane is required to inform employees about the general provisions of this law, perhaps the most important aspect of training is imparting knowledge and understanding on the specific dangers of the chemicals and materials with which employees work, and establishing a means of protecting the employees from these dangers.
HAZCOM is the most frequently cited standard in enforcement actions pursued by OSHA. Common violations include lack of a written hazard communication program, lack of SDSs, inaccessible SDSs, and incorrect labeling of containers. Each missing SDS or container label, or each employee who has not been trained constitutes a separate violation, with a minimum penalty of $5000 for each willful violation, and an allowable civil penalty of $70,000 for each willful violation.C. What Materials are Exempt?
The HAZCOM Standard identifies certain materials which are exempt from the regulations:
- Hazardous waste and certain other substances regulated by the Environmental Protection Agency (EPA)
- Tobacco and tobacco products
- Wood and wood products unless treated with a hazardous chemical (Note: Sawed or cut wood, generating dust, is not exempted.)
- Articles (manufactured items which, under normal conditions of use, do not release more than minute quantities of a hazardous chemical and do not pose a physical or health risk)
- Food or alcoholic beverages
- Drugs in solid form for direct administration to the patient (e.g., tablets or pills, over-the-counter drugs, and first aid supplies)
- Any consumer product or hazardous substance where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer and the use results in a duration and frequency of exposure which is not greater than the range that could be reasonably be experienced by consumers when used for the purposes intended
- Nuisance particulates where they do not pose any physical or health hazard
- Ionizing and nonionizing radiation
- Biological hazards
Laboratories fall under the OSHA Laboratory Standard29 CFR 1910.1450 and must comply with the provisions of that standard. Under HAZCOM the following provisions apply:
- Laboratory employees must not remove or deface labels on incoming containers of hazardous chemicals.
- SDSs must be readily accessible to laboratory employees when they are in their work areas. Work Area is defined by OSHA as a room where hazardous chemicals are used and where employees are present.
- Laboratory employees must be provided with information and training.
- Laboratory employees that ship hazardous chemicals are considered to be a chemical manufacturer or distributor, and thus must ensure that any containers of hazardous chemicals leaving the laboratory are labeled and that an SDS is provided along with the shipment.
In work operations where employees handle chemicals in sealed containers which are not opened under normal conditions of use such as are found in shipping and receiving or retail sales (e.g., Bookstore), the following rules apply:
- Labels on incoming containers of hazardous chemicals must not be removed or defaced.
- Copies of SDSs that are received with incoming shipments of the sealed containers of hazardous chemicals must be readily accessible to employees when they are in their work area. If a sealed container of hazardous chemicals is received without an SDS, it shall be obtained as soon as possible if an employee requests it.
- Employees shall be provided with information and training to the extent necessary to protect them in the event of a spill or leak of a hazardous chemical from a sealed container (i.e., evacuate the area and contact the Office of Environmental Health & Safety for spill cleanup).
HAZCOM provides for the protection of trade secrets. Specific chemical identity may be withheld from an SDS if the trade secret claim can be supported, the SDS indicates that the identity is being withheld as a trade secret, and the SDS includes information on the hazardous properties and effects of the trade secret chemical. However, the trade secret must be divulged to the treating medical health professional in a medical emergency when immediate disclosure of the chemical identity is necessary for first aid or emergency treatment. The chemical manufacturer, importer, or employer may require a written statement of need and confidentiality agreement as soon as circumstances permit.
In non-emergencies, the health professional, employee, or designated representative may provide a written request for disclosure of a chemical's identity but must explain why the disclosure is essential, must describe the procedures which will be followed to protect the confidentiality of the information, and must be bound by a written confidentiality agreement. This written request can be denied, but the manufacturer must explain why the request is being denied as well as an explanation of how alternate information will satisfy the specific occupational or medical need. The person being denied may contact OSHA to review the request and denial.II. Tulane’s HAZCOM Program
Tulane has developed a written HAZCOM program which is available to all persons at Tulane as part of the Tulane University Environmental Health & Safety Policies and Procedures Manual. As part of this plan, Tulane relies on the hazard determination performed by the chemical manufacturer and summarized in the SDS. Tulane’s written HAZCOM plan contains information on maintaining hazardous chemical inventories, accessibility of SDSs for all employees, labeling of chemical containers and other forms of warning, and implementation of employee training programs which address the hazards of chemicals and protective measures. It also discusses contract workers and Tulane's and the contract company’s mutual obligation to provide HAZCOM information while on Tulane property.
All employees must be aware that Tulane has a written Hazard Communication Plan and must know where it can be found.
The SDS is the primary document in hazard communication. The HAZCOM Standard requires manufacturers and distributors to provide SDS's with the chemicals they produce or ship (initial shipment and with the first shipment after an SDS is updated). It also requires employers to provide SDSs in the workplace and to make them easily accessible in the work area for each hazardous chemical that is used. (Work Area is defined by OSHA as a room where hazardous chemicals are used and where employees are present.) If an SDS for a hazardous chemical is not provided with a shipment, Tulane must obtain one from the manufacturer or distributor as soon as possible. Manufacturers must also provide SDSs upon request.
Tulane’s Office of Environmental Health & Safety (OEHS) maintains a set of hard copies of SDS's in the main office (Tidewater, Suite 1156) and provides access to SDSs on its website for all chemicals listed on the complete Tulane chemical inventory. If you have trouble obtaining an SDS, please call OEHS at (504)988-5486. After hours, please contact Tulane Police who can contact an on-call member of the OEHS staff for assistance. It is imperative that each work area have access to SDS's for chemicals used in that area so that critical information is easily available.
The importance of the SDS cannot be overstated. This form contains important hazard and protection information on a hazardous chemical. While workers will need training to learn to understand the SDS format and the proper ways to protect themselves, the document itself is the basic guide to chemical safety. It's the one place everyone should look before starting any job involving hazardous chemicals and anytime there is a question about a particular chemical's risks or means of protection. Making the SDSs available and accessible helps to ensure that employees are informed of the hazards in their work areas and the proper means of protecting themselves.
As part of a written hazard communication program, OSHA requires a list of hazardous chemicals known to be present in the workplace and work areas. By submitting an inventory of hazardous chemicals to OEHS, OEHS is able to maintain a set of hard copies of SDSs for all hazardous chemicals on Tulane’s campuses and ensures that electronic access to the SDSs is available. Serious delays in response could result in an emergency if a chemical inventory is not submitted. The local fire department has requested that Tulane provide lists of chemical hazards to firefighters for emergency preparedness. OEHS also uses the chemical inventory lists for federal, state, and local reporting requirements. It is in the best interest for all entities at Tulane in operations where hazardous chemicals are used to provide an annual chemical inventory list to OEHS.
Tulane's complete hazardous chemical inventory is comprised of individual inventories submitted to OEHS. The principle investigator, supervisor, or departmental safety representative (DSR) is responsible for ensuring that these individual inventories are submitted to OEHS and that they are updated annually. Electronic submittal (Excel, Paradox, Access, etc.) of the chemical inventory is preferred. A chemical inventory formwhich can be used as a guide is available on the OEHS website. Remember when compiling inventories, only hazardous chemicals need to be reported and certain materials are exempt. A copy of the individual inventory should be kept in the work area.
Tulane’s complete hazardous chemical inventory list is maintained by OEHS. Copies of the inventory list have also been given to Tulane Police on the various campuses for placement in the fire packets for different buildings.
Container labels makes it easy for workers to identify the hazards associated with each chemical and to plan the protective measures they'll take before beginning their work. Container labels are an essential information source and one of the key parts of the hazard communication system. HAZCOM distinguishes two set of label requirements: one for primary containers (from the manufacturer) and one for secondary containers (often called transfer containers).
Primary containers (received from a manufacturer or distributor) must be labeled or marked with:
- the chemical's identity (full name, no abbreviations or symbols)
- the name and address of the manufacturer
- appropriate hazard warnings (physical and health hazards, e.g., flammable, corrosive, toxic, carcinogen, etc.)
Secondary containers must be labeled or marked with:
- the chemical’s identity (full name, no abbreviations or symbols)
- appropriate hazard warnings (physical and health hazards)
Never remove or deface a manufacturer's label from a container unless the container is immediately marked with the required information or unless the container is empty. (This is also a Department of Transportation (DOT) requirement.)
Secondary containers into which hazardous chemicals are transferred from labeled containers and which are intended only for the immediate use of the employee who performs the transfer need not be labeled, according to the HAZCOM Standard. Secondary containers which will be used by more than one person or which will be left over a period of time must be properly labeled as indicated above. OEHS has developed a label for use with secondary containers. You may also use your own label as long as the required information is included. Again, the label must identify the chemical and must list the physical and health hazards associated with the chemical. Additional information such as personal protective equipment required for handling the chemical safely or target organs associated with the use of the chemical, is optional. Information for the secondary container label can be obtained from the source label on the original container or from the SDS.
Signs or placards may be used in lieu of affixing labels to individual secondary containers, as long as the alternative method identifies the containers to which it is applicable, conveys the information required, and everyone in the work area is familiar with the alternate labeling system. All labels, whether primary or secondary, must be legible, in English, and prominently displayed.
In the event that a manufacturer or Tulane becomes newly aware of any significant information regarding the hazards of a chemical, the label for that chemical must be revised within three months of becoming aware of the new information, and all new shipments of the chemical from the manufacturer must contain the new information. OEHS will identify users of the chemical (based on the Tulane complete hazardous chemical inventory list) and notify the users of any required labeling changes when Tulane becomes aware of such changes.
OSHA requires containers which hold substances known to be carcinogenic or reasonably anticipated to be carcinogenic by the National Toxicology Program (NTP) to have carcinogen warnings on their labels. International Agency for Research on Cancer (IARC) listed chemicals in groups 1 and 2A must also have carcinogen warnings on the labels and SDSs, whereas 2B chemicals need be noted only on the SDS. If a hazardous chemical is regulated by OSHA in a substance-specific standard (e.g., benzene, formaldehyde, ethylene oxide, acrylonitrile, asbestos), the specific labeling marking and language for that substance must appear on the container. Also, entrances to regulated areas should be posted with signs stating, "Cancer-Suspect Agent, Authorized Personnel Only." For more information on labeling carcinogens and regulated areas, see the substance-specific OSHA standard for that material, the OSHA Laboratory Standard, and Tulane’s Chemical Hygiene Plan.E. Employee Information and Training
All employees of Tulane who handle chemicals must be trained to:
- Recognize hazards
- Understand and use the information on container labels and SDS's
- Know how to protect themselves from chemical hazards
- Know what to do in a chemical emergency
At the heart of HAZCOM is employee training requirements. The OSHA HAZCOM Standard is "performance oriented" which means that employers have the flexibility to adapt the rule to the needs of the workplace, rather than having to follow specific, rigid requirements. OSHA inspectors have the right to interview employees and judge how well they understand on-the-job hazards and protective measures. These employee interviews will determine if Tulane has provided an adequate training program.
Principle investigators, supervisors and DSRs play a key role in training. OEHS provides general safety training on hazard communication to new employees at orientation. In addition, OEHS providesonline training on HAZCOM on its website, tulane.edu/oehs. In-service training on HAZCOM is provided by OEHS upon request.Principle investigators, supervisors, and DSRs are essential in communicating specific information to their workers. Principle investigators, supervisors and DSRs are responsible for ensuring that workers are trained on the hazards specific to their work area and on adequate means of protection from these hazards. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and SDSs.
Principle investigators, supervisors, and DSRs must ensure training takes place when a new employee is assigned to their department and whenever a new hazard is introduced into the work area. OEHS recommends annual review of chemical hazards and proper protection procedures.
All safety training must be documented. A training documentation form is available on the OEHS websitefor documenting in-service training which is done. In addition, the HAZCOM online training course available on the OEHS website has a quiz which links to a database that maintains training records of those who successfully complete the course.
During training, employees must be informed of the following:
- The existence of and requirements of the OSHA HAZCOM Standard, 29 CFR 1910.1200
- Any operations in their work area where hazardous chemicals are present
- The location and availability of Tulane's written HAZCOM Program (Tulane University Environmental Health & Safety Policies and Procedures Manual)
- The details of Tulane’s HAZCOM program including labeling, SDSs, and how employees can obtain and use the appropriate hazard information
- Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring by OEHS industrial hygienists, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.)
- The physical and health hazards of chemicals in the work area
- The measures employees can take to protect themselves from hazards, including specific procedures such as engineering controls (ventilation, fume hoods, etc.), appropriate work practices, emergency procedures, and personal protective equipment (PPE) to be used
The following information must also be transmitted to employees:
- The hazards of non-routine tasks such as entering confined spaces or working with rarely used chemicals. Whenever employees need to perform tasks that are not part of their normal work duties, they should check with their supervisor, principle investigator, or departmental safety representative (DSR) for safety information, personal protective equipment, and other necessary precautions they may need to take.
- The hazards associated with chemicals in unlabeled pipes in the work area. Facilities Services should be able to identify the pipes in your work area and let you know if any hazards are associated with them.
- Your specific area's emergency procedures. Principle investigators, supervisors, and DSRs are responsible for informing employees of building evacuation, spill, and other emergency procedures specific to their particular work area. General emergency procedures can be found in the University’s Environmental Health & Safety Policies and Procedures Manual.
Training aides such as videos, booklets, web links, etc. to assist in your training are available from OEHS. Remember, knowledge acquired under the HAZCOM Standard can help provide a safer workplace, can help reduce exposures to hazardous materials, and can help in the establishment of proper work practices.
Contract employees who could be exposed to hazardous chemicals on site here at Tulane must be given the opportunity to review a copy of Tulane's written Hazard Communication Program and must be told about the particular hazards associated with the work areas in which they will be working so that they can take the proper precautions. SDSs must be made available to them when requested and all chemicals they may contact must be labeled.
On the flip side, contractors must list and provide SDSs for all hazardous chemicals that are to be used by their employees in the course of their work on Tulane property so that Tulane employees may receive the necessary information and training concerning the potential hazards of the substances to which they may be exposed.
Facilities Services and other contracting departments are responsible for seeing that this transfer of information takes place. Tulane's Hazard Communication Policy contains an addendum for contractual agreements and lists contacts for both Tulane and the contracting company who are responsible for this exchange of this information. Those who need assistance in the implementation of this policy should contact OEHS.
1. Ensure all employees are aware of the OSHA HAZCOM Standard and Tulane’s written HAZCOM Program.
2. Ensure all containers in the area you represent are properly labeled with the full name of the chemical (no abbreviations or symbols) and the associated hazards, and that employees understand the labels.
3. Complete (or have persons you are representing complete) an annual chemical inventory for all hazardous chemicals in the work area and/or department and submit a copy (preferably an electronic copy) to OEHS. Keep a copy of the annual chemical inventory in the work area.
4. Check to see that you and all of the people you represent have easy access in the work area to all necessary SDSs for those chemicals that are listed. If some SDSs are missing, notify OEHS to contact the manufacturer in order to obtain the missing sheets. Everyone in the work area must know how to obtain a copy of an SDS.
5. Inform all employees that a complete set of hard copy SDSs is located at OEHS (Main Office, Tidewater Suite 1156). After hours, contact Tulane Police who can contact the on-call member of the OEHS staff in the event of an emergency.
6. Train employees about the hazards associated with the specific chemicals in the work area and department. Make sure that they know what personal protective equipment is available, appropriate, how to properly use it, and where it is located. Remember that training on HAZCOM is available online at the OEHS website tulane.edu/oehs,that in-service training is available from OEHS upon request, and that other training materials are available from OEHS to assist you. Ensure new employees are trained, and that training is done when new hazards are introduced.
7. Make sure all training sessions are documented to ensure compliance. Annual review of chemical hazards and proper means of protection is highly recommended.
8. If your department contracts with outside contractors, remember that these contract employees must be given the opportunity to review Tulane's written Hazard Communication Plan and any applicable SDSs, and in turn must provide Tulane information on hazardous materials they bring on site. Contact OEHS for more information.
Several systems and standards for labeling chemicals to communicate their hazards have been developed and used over the years, but there currently is not a uniformly accepted system, although a global system is in the process of being developed and approved. Each system and standard has advantages and limitations. This supplemental section on labeling describes some of the most commonly used systems.
Precautionary labeling for hazardous materials has been developed by the Chemical Manufacturers Association (CMA) and the American Conference on Chemical Labeling and adopted as American National Standards (Z129.1) by the American National Standards Institute (ANSI) (see www.ansi.orgfor information and to order ANSI standards).This precautionary labeling contains the name of the chemical, a signal word such as WARNING or DANGER, the key hazard such as flammable or vapor harmful, and statements of precautions to avoid the hazard. The use of a single term will not always provide adequate information because many chemicals have multiple hazards. Another problem is that the term corrosive includes materials that may be incompatible with one another. For example, strong mineral acids (hydrochloric acid) and strong alkaline materials (sodium hydroxide) are both corrosive but if they mix during storage or use, they will react vigorously.
The National Paint and Coatings Association (NPCA) uses the Hazardous Materials Identification System (HMIS), one of the most popular systems for labeling. This system uses standard labels to communicate hazards through the use of colors, numbers, letters of the alphabet, and symbols. The HMIS label is a 5-part rectangle that provides identification of the chemical; acute health (blue), flammability (red), and reactivity (yellow) numerical ratings (0 is minimal, 4 is severe); personal protective equipment alphabetical designations; and chronic health hazard information.
The National Fire Protection Association uses a color-coded system called NFPA 704. The system uses a color-coded diamond with a numerical rating system to identify the degree of health (blue), fire (red), or reactivity (yellow) hazards which may be encountered during short-term fire related exposures. It provides space for other hazards such as water reactives or oxidizers. Hazards are rated from 0 which is minimal to 4 which is severe in each of the above listed categories. The NFPA diamond is used primarily by emergency response personnel and for emergency planning and does not adequately signal occupational hazards or precautionary information. It is good for alerting personnel to the degree of hazard of the chemical and helpful in drawing attention to storage needs and emergency equipment needed.
The Department of Transportation (DOT) labeling system (see p. 18-19 of the 2004 DOT Emergency Response Guidebookuses a color-coded diamond in which there is a symbol and a term describing the major hazard of the material. DOT hazard classes include explosives, gases (flammable, nonflammable, corrosive, and poison), flammable liquids, flammablesolids, oxidizers, poisons, radioactive materials, and corrosives. Although the major hazard is listed, many chemicals have subsidiary hazard categories as well. The DOT system is used for the transportation of hazardous materials.
The Globally Harmonized System (GHS) currently being developed and approved is a system being designed to protect the health and environment and to facilitate global trade in chemicals. It includes internationally agreed upon cautionary statements as well as symbols/pictograms for chemical properties such as environmental toxicity. The United States is working toward adoption and implementation of this promising system at the current time (seea Guide to the Globally Harmonized System of Classification and Labeling of Chemicals).
SDSs are required to contain certain information, but there is no standardized format at the present time. Variations between manufacturers can cause SDSs to be very difficult to use. According to OSHA, SDSs must be in English, must be complete, and there can be no blank fields on the SDS. OSHA published a recommended SDS format in 1985, OSHA 174. In addition, ANSI, the American National Standards Institute, has a format for development of SDSs. The ANSI standard (Z400.1-1998) (see www.ansi.orgfor information and to order ANSI standards) was drafted by the Chemical Manufacturers Association and is optional. There are also talks in progress for a global SDS formatsimilar to the Globally Harmonized System (GHS) for labeling chemicals (seea Guide to the Globally Harmonized System of Classification and Labeling of Chemicals). To this end, International Chemical Safety Cards (ICSCs)are now available from the National Institute for Occupational Safety and Health (NIOSH) on over 1300 substances in 14 languages. These safety cards include OSHA Permissible Exposure Limits (PELs), NIOSH recommended Exposure Limits (RELs), Immediately Dangerous to Life and Health (IDLH) data, and links to the NIOSH Pocket Guide to Chemical Hazards.
On the OEHS website, a link to an SDS HyperGlossaryis provided. Everyone should become familiar with terms on the SDS with which they are not familiar.
Manager, Chemical Safety
Office of Environmental Health & Safety
1430 Tulane Ave., TW16
New Orleans, LA 70112