When OSHA adopted the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS) workplaces probably saw the biggest change in workplace safety that we have seen since the PSM standard. One of the biggest changes came with the new Safety Data Sheet (SDS) format and for some reason, many “responsible parties” felt the need to no longer include NFPA 704 and/or HMIS labeling information on their new SDS. In the good old days, NFPA 704/HMIS label information was readily available on most MSDSs, but today it seems to be near impossible to find this information on the new SDS’s. Recently, a “responsible party” told a client that they were “no longer permitted by OSHA to include NFPA 704/HMIS information since the labels were no longer allowed to be used in the workplace”. This is a complete fabrication, as OSHA makes it clear that “responsible parties” can include NFPA 704/HMIS labeling data on their SDS(s) and as my previous posting made clear – NFPA 704/HMIS are still viable labeling for secondary containers…
Section 2 – Hazard(s) identification
The classification must include the class and the category, e.g., Flammable Liquid, Category 1.
Hazard not otherwise classified (HNOC)
HNOC must be listed in section 2 of the SDS. As HNOCs are identified through the 1910.1200(d) hazard classification process, it is permissible to include information on HNOCs under subheading (a).
The manufacturer, importer or distributor may include hazard symbols on the label or SDS for HNOCs as long as that symbol is not an HCS 2012 pictogram and does not contradict or cast doubt on the information that is required.
Precautionary statements are not required for combustible dust hazards and, therefore, none are required in section 2 of the SDS if combustible dust is the only hazard listed.
Pictograms/symbols
Appendix D of the HCS, section 2, states, “Hazard symbols may be provided as graphical reproductions in black and white or the name of the symbol, e.g., flame, skull, and crossbones.” The hazard symbol is the symbol inside the frame of the pictogram. Therefore, just the symbol can be used, or the name of the symbol can be used.
If the pictogram is used, it may be printed in black and white.
If additional information is added to the required hazard statements or precautionary statements on the label, it is consistent to include that language on the SDS.
Responsible parties may add their own precautionary statements to section 2 of the SDS so long as they are relevant and do not contradict or cast doubt on the validity of the other information in the SDS.
Responsible parties may include rating systems (e.g., HMIS, NFPA) in section 2 of the SDS as long as they do not contradict or cast doubt on the HCS 2012 classification.
I find it infuriating that with all the new GHS categories that many “responsible parties” are no longer providing this key data. I even struggle to determine the proper ratings from an SDS for NFPA 704 Diamonds; so expecting a worker to be able to translate SDS data into NFPA/HMIS ratings in a timely manner may be expecting too much!!