MATERIAL SAFETY DATA SHEETS

FREQUENTLY ASKED QUESTIONS

Presented below, arranged according to applicability to specific sections of the ANSI 16-part MSDS, are questions, and answers, which CHEMICAL SAFETY ASSOCIATES, Inc. (CSA) frequently is asked concerning MSDSs.

December 31, 1996

Are MSDSs subject to the Record Retention Requirements of 29 CFR 1910.20?

OSHA gave employers two options under the record retention requirements for records of exposure data. The first, and preferred option, is to keep a record of the chemical(s), the time of use, and the location. The second option is to maintain a copy of the MSDS. The wording of the regulation is such that, if the second option is used, no "when" and "where" information is needed. In either case, employee exposure records must be retained for 30 years, after the employee leaves employment. This is discussed in an internal OSHA memorandum, dated December 12, 1986 from Jon Miles to Frank Strasheim. The memorandum is available on the OSHA CD-ROM.

Section 1. Chemical Product and Company Identification

Is a 24-hour Emergency Number Required?

No. The MSDS must have an emergency telephone number, but it does not have to be attended 24 hours per day. Actual times of availability may be listed in proximity to the emergency telephone number. Do not confuse this requirement with the Department of Transportation requirements (49 CFR 172.201) for a 24-hour emergency number on all hazardous material shipping papers.

Section 2. Composition and Information on Ingredients

Must I disclose all components of a mixture?

OSHA requires that all hazardous components in excess of 1% be disclosed (addressed) on the MSDS. Carcinogens in excess of 0.1% must be disclosed. OSHA defines a "hazardous" chemical very broadly. According to the OSHA definition, any chemical which could possibly cause any physical or health effect under expected conditions of use or reasonably anticipated conditions of misuse are hazardous.

The following summarizes the parameters for listing a compound on the MSDS (per the regulations of the Hazard Communication Standard, 29 CFR 1910.1200, Mandatory Appendices A and B).

* There are established exposure limits for any component of this product (specifically: Threshold Limit Values, American Conference of Governmental Industrial Hygienists; Permissible Exposure Limits; Occupational Safety and Health Administration; Recommended Exposure Limits; National Institute of Occupational Safety and Health; Maximum Exposure Level, National Republic of Germany).

* A component of this product is listed by the following agencies to be potential cancer hazards: National Toxicology Program, International Agency for Research on Cancer, the Occupational Safety and Health Administration, the National Institute for Occupational Safety and Health; or the California Occupational Safety and Health Administration.

* A component of this product is known to be a human reproductive toxin.

* A component of this product is on the California Proposition 65 List.

* A component of this product has reporting requirements under the Environmental Protection Agency's Superfund Amendment and Reauthorization Act (Sections 302, 304, or 313) or Clean Air Act (Section 112 (r)).

* A component of this product is present in concentrations greater than 1 percent.

Note: The reason for this last parameter is the very broad definition of "health hazard" for chemicals (either tested or untested) in Appendices A and B and the Hazard Communication Standard. A compound is deemed to be "non-hazardous" by OSHA only if it does not produce any of the following health effects.

- It is not a carcinogen or a potential carcinogen.

- It is not corrosive.

- It is not highly toxic (LD₅₀ (oral, rat < 50 mg/kg; LD₅₀ (skin, rabbit) < 200 mg/kg; LC₅₀ (inhalation, rat) < 200 ppm).

- It is not an irritant (there is a specific test for eye and skin irritancy conducted on rabbits).

- It is not a sensitizer.

- It is not toxic (LD₅₀ (oral, rat) = 50-500 mg/kg; LD₅₀ (skin, rabbit) = 200 - 100 mg/kg; LC₅₀ (inhalation, rat) = 200 ppm - 2000 ppm).

- The chemical has no TARGET ORGAN EFFECTS. This includes any affect on the skin or respiratory system.

Must I disclose the exact composition (percentages) of the components of a mixture?

No. You can provide the composition information in terms of a range (eg. 10 - 15%). It is CSA's practice to use a 10% range, not necessarily centered on the actual composition.

Is it possible to protect component information by a claim of "Proprietary Information"?

Yes. OSHA allows claims of trade secrets and proprietary information. However, the manufacturer must abide by a variety of Federal standards on trade secrets. In addition, the manufacturer must be prepared to provide full disclosure of the composition in the event of a request from a health care provider. A number of states, such a New Jersey, Pennsylvania, and New York (to name just a few), require specific registration of the product with the state, if a trade secret claim is to be made.

It is CSA's practice to prepare a full-disclosure MSDS and then use it to prepare the proprietary version. This provides the manufacturer with all of the information needed.

Section 3. Hazards Identification

Is testing required to identify hazards?

OSHA does not require testing, if other information is available which allows a hazard determination to be made.

How does CSA perform the hazard assessment, especially for mixtures?

CSA uses all of the information provided by our client, including the exact composition and MSDSs for all raw materials, and adds to this, information derived from our internal resources including Sax Dangerous Properties of Industrial Materials and the Registry of Toxic Effects of Chemical Substances (RTECS), among others. CSA uses all of this information to identify physical hazards and specific acute or chronic health hazards. If specific testing is needed, to determine a DOT Proper Shipping Name, for example, we advise our client of this, and recommend a laboratory to do the testing.

Section 4. First-Aid Information

Employees frequently get small amounts of chemicals on their skin during routine industrial operations. Must such routine exposures be rinsed off for 15 minutes? What is the source of the 15-minute rinse recommendation?

All industrial operations should be designed to prevent all skin contact with all chemicals. However, many operations, especially those involving paints, oils, and greases, do result in skin exposure. Such exposures should be thoroughly rinsed with soapy water. Any exposure which causes any irritation or health effect must be thoroughly rinsed and the employee should seek medical attention.

What is the source of the 15-minute rinse recommendation?

The 15-minute minimum rinse recommendation is generally accepted throughout industry. No single original citation exists. However, widely accepted references, such as the Sigma-Aldrich Library of Chemical Safety Data (Ed. II, Robert E. Lenga, ed.), Prudent Practices for Handling Hazardous Chemicals in Laboratories (First and Second Editions, National Academy of Sciences), and Hazardous Materials Injuries (D.R. Stutz, R.C. Ricks, and M.F. Olsen) all recommend using at least a 15-minute rinse, followed by medical evaluation.

Section 5. Fire and Explosion Hazards

Why do the NFPA and HMIS ratings not agree?

The NFPA and HMIS rating systems are targeted at different audiences. They have similar appearances and similar interpretations, but they are essentially different. The NFPA rating system is directed at providing immediate information to fire-fighters responding to a fire which may involve hazardous materials. The HMIS rating system is directed toward providing persons using chemical products with general information related to safe use of the product. The NFPA rating is primarily based on flash point and LD₅₀ (lethal dose for 50% mortality) information. The HMIS information uses a wide variety of acute health effect parameters, as well as the same fire and reactivity parameters used by the NFPA system. Thus, ratings are frequently different.

Section 6. Accidental Release Measures

Why are triple-gloves recommended for spill response?

The US Coast Guard, EPA, NIOSH, OSHA document Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities recommends inner and outer chemical protective gloves for Level A (full encapsulating, vapor-tight protection) and Level B (high level protection, which is not vapor-tight) protection. In practice, a pair of light-weight inner liners, made of an impervious material such as nitrile or latex, is typically worn under the inner chemical protective gloves. This pair of inner gloves are the last piece of protective equipment removed, prior to exit from the Decontamination Corridor. They are considered part of the inner clothing, which is not expected to become contaminated.

What are the levels of personal protective equipment and are these levels generally recognized?

The language associated with four levels of personal protective equipment is specific to responses to accidental releases and to protection at EPA "hazardous waste sites". The language has become standardized by all regulatory agencies, as a result of the publication Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities. LEVEL A protection provides the highest level of respiratory, eye and skin protection. LEVEL B protection provides the same level of respiratory protection but less skin protection than LEVEL A. It is generally recommended for the initial site entries, until the hazards have been further identified. LEVEL C protection provides the same skin protection as LEVEL B, but a lower level (air purifying respirator) of respiratory protection. LEVEL D protection is normal work clothing, which provides no respiratory protection and minimal skin protection.

Why is LEVEL B protection recommended for initial response to a chemical spill?

LEVEL B protection is the level of protection used as a standard throughout industry in the U.S. when dealing with a poorly or incompletely characterized spill situation. Until such time in a spill response that the scene is fully characterized, by monitoring, or in the judgement of an appropriately trained person, the protection offered by Self-Contained Breathing Apparatus (SCBA) should be used. In addition, OSHA requires, at 29 CFR 1910.120(q)(3)(iv): "Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard shall wear positive pressure self-contained breathing apparatus while engaged in emergency response, until such time that the individual in charge of the ICS {Incident Command System} determines through use of air monitoring that a decreased level of respiratory protection will not result in hazardous exposures to employees." Based on this language, it is CSA's opinion that the MSDS must recommend LEVEL B protection for all but the lowest risk products.

Section 7. Handling and Storage

No entries at this time.

Section 8. Exposure Controls - Personal Protection

No entries at this time.

Section 9. Physical and Chemical Properties

If a manufacturer does not have (know) specific physical and chemical properties, must testing be performed?

No. The MSDS can state "Not available", if specific information is not known. However, providing as much information as possible is the preferred procedure for MSDS preparation.

Section 10. Stability and Reactivity

No entries at this time.

Section 11. Toxicological Information

Must a manufacturer perform toxicological studies of a mixture?

No, according to OSHA. If specific toxicological data are not available on the product, the MSDS can report available information for the components, which are listed in Section 2 of the MSDS.

Section 12. Ecological Information

No entries at this time.

Section 13. Disposal Considerations

No entries at this time.

Section 14. Transportation Information

How is the Transportation Information determined for the MSDS?

CSA uses the composition and hazard information from Sections 2 and 3 of the MSDS to derive an applicable Proper Shipping Name from 49 CFR 172.101. This then provides all other required information. CSA further applies the DOT regulations to address limited quantities, as applicable. CSA uses the Canadian Transport of Dangerous Goods (TDG) regulations for Canadian transportation information.

Section 15. Regulatory Information

Why does CSA include state-specific regulatory information?

OSHA does not require specific regulatory information to be included on the MSDS. However, to meet the recommendations of the American National Standard, ANSI Z400.1-1993 on Material Safety Data Sheet Preparation, this information is included. CSA attempts to provide a thorough regulatory review for each MSDS in this section.

Section 16. Other Useful Information

No entries at this time.