SDS & Right-to-Know
Chemical inventories are required to be completed by nearly every employer. A list of chemicals in the workplace is required to be provided under the Hazard Communication Regulation (29 CFR 1910.1200). Under Pennsylvania's Right-to-Know law, a Hazardous Substance Survey Form (HSSF) needs to be completed annually by April 1. Safety Data Sheets (SDS under the new Global Harmonization Standard) are required to be available for most all materials to which employees potentially could be exposed.
We start by taking a physical inventory of all of your materials. Next the HSSF form is developed and populated with regulated chemicals. Next we compare the inventory list to your existing SDS sheet inventory. If sheets are missing we request them. If desired we can also update old sheets which are likely out of date. We assemble the SDSs and books in a format which we previously determined. Completed SDS books are provided. This is a time consuming process, that many facilities do not have the staff to perform. In addition, our staff have extensive experience in locating and accessing SDS.
As a supplement to the chemical inventory, High EH&S consulting can perform a Chem-Check to ensure that the most hazardous chemicals are identified and if possible, removed from your facility. This process scans for highly regulated chemicals, materials with extremely low permissible exposure limits as well as any materials which are known to be human carcinogens. This process is specifically recommended for schools which want to maintain a greater awareness about the materials to which students are being exposed.
Facilities regulated under the state (PA, NJ) Right-to-Know law are required to conduct training annually. We can provide this annual training or for those facilities regulated under OSHA, we can provide periodic update training. Under the GHS changes, re-training must be provided to all employees whose workplaces are regulated under OSHA, by December 2013.
SDS and Label Development
Under OSHA's new Global Harmonization Standard, Material Safety Data Sheets (MSDS) will become Safety Data Sheets (SDS). Manufacturers and distributors of products and chemicals which have downstream users (customers) who require an MSDS will have until June 1, 2015 to have new SDS developed. The SDS provides a highly defined format in which product information must be provided. The new format is only a small part of the story. The larger hurdle in the development of these SDS is the hazard classification. In the previous hazard communication standard, the employer could rely on various sources of hazard information to convey the hazards of the products to the end-user. This approach is now very defined and MUCH more involved than what past hazard determinations usually involved. Component ingredient information will be derived from toxicological and epidemiological studies. Individuals performing classifications will need to be familiar with toxicological risk assessment methodologies as well as how to evaluate the weight of evidence scientific studies. The health hazard classification section of the new standard entails 68 pages of directions. Additional assessments for physical hazards and characteristics must also be addressed. Proper review and assessment will take more time and be more costly than in the past. For ingredients which are not well classified, the challenge is even greater. We can assist bringing your old MSDS up to the SDS formats. The new GHS labels are also based on the hazard classification process and so often, label development is included in the SDS development project. If you are providing a consumer product, we can also assist in developing labels which meet the Consumer Product Safety Commission (CPSC) labeling rules.