By Ken Roy
Posted on 2023-05-26
The 2012 revision of Occupational Safety and Health Administration (OSHA) Hazard Communication Standard [29 CFR 1910.1200(g)] stipulates that chemical manufacturers, distributors, or importers must provide the Safety Data Sheets (SDSs, formerly known as the Material Safety Data Sheets or MSDSs) for any chemical that an employee or student could be exposed to. The purpose of SDSs is to communicate specific information on chemical potential hazards and resulting risks. They provide information about the chemical: e.g., common and chemical names, physical properties, health hazards, reactivity information, control measures, and other pertinent information.
OSHA’s Hazard Communication Standard and the occupational exposure to hazardous chemicals in laboratories or Laboratory Standard (29CFR 1910.1450) require an employer to secure an SDS when purchasing a new chemical from a manufacturer or supplier. The employer must then make the SDS available to the employee who will use the chemical or be exposed to it in some way in the workplace.
In K–12 school laboratories (science, technology education/engineering, STEM/STEAM, etc.), SDSs are critical to the Laboratory Standard’s required Chemical Hygiene Plan. Having quick access to the SDS is a priority because exposure to certain potential hazardous chemicals can be life threatening for both employees and students. In the spirit of the standard, teachers should keep a folder of SDSs for chemicals being used during an investigation or demonstration in the laboratory. If an accident were to occur, the teacher could simply send the person exposed to the chemical along with the SDS to the nurse or to the emergency medical service personnel. Minimally, an SDS notebook of all chemicals used in the laboratory should be easily accessible and available in the science workroom or office areas. Electronic versions are also acceptable and can be shared with the town’s fire marshal.
It is recommended that school purchase orders have a printed statement noting that SDSs are required for all chemicals, and payment for chemicals will be withheld until SDSs are provided. If a chemical is purchased at a local store, the SDS needs to be secured. Consider the scenario in which an employee brings the chemical into the workplace and another employee is allergic to it. Remember that everyone has the legal right of access to this information as stated in the Title III of the Superfund Amendments and Reauthorization ACT (SARA), commonly referred to as the Right to Know Act, which allows communities to be made aware of and be protected from any chemical hazards.
OSHA Standards require the employer to train employees each time a new chemical is introduced into the workplace environment. Chemical Hygiene Officers or safety officers are required to have documentation of such training programs. It is wise to include a standing agenda item on safety in writing for each department meeting. During these sessions, new chemicals and precautions can be addressed.
It would also be prudent to have other chemical reference material above and beyond the SDSs available. OSHA compliance officers may ask to see these during inspections. The bottom-line is accessibility to chemical reference information like the SDS and training for employees when new chemicals are introduced into the workplace. Training is also required for new employees entering the workplace.
As was noted, SDSs are required to be presented in a consistent user-friendly 16-section format. Included are the following sections:
Each section contains important information that can help make the laboratory safer. For example, Sections 1 through 8 contain general information about the chemical manufacturer, identification, hazards, composition, safe handling and storage practices, and emergency control measures (e.g., firefighting). Section 8 details Permissible Exposure Limits (PELs) and Threshold Limit Values (TLVs) of that specific chemical, as well as any relevant recommended personal protective equipment (PPE). Sections 9 through 11 and 16 contain additional technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information.
Although not enforceable under OSHA mandates, Sections 12 through 15 are required in concert with the United National Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and are handled by other government agencies. Section 13 provides a description of the recommended method for disposing of the chemical. However, absent a specific disposal method, one should contact the designated Chemical Hygiene Officer or safety officer and follow any respective local municipality, state, and federal disposal method recommended.
For specifics on each section, see the follow OSHA resource: Hazard Communication Standard: Safety Data Sheets
https://www.osha.gov/sites/default/files/publications/OSHA3514.pdf and from 29 CFR 1910.1200 Appendix D, https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppD.
To determine if the laboratory investigation or demonstration is safer to involve students, teachers need to apply the triple “A” procedure: AAA—Awareness, Assessment, Action. For potential chemical hazards, there is a critical reference role for SDSs. The components of this approach are Hazard Analysis, Risk Assessment, and Safety Action.
(a) Hazard Analysis. Identify chemicals to be used, amounts required, and circumstances of use in the experiment. Consider any special employee or laboratory conditions that could create or increase a hazard. Consult sources of safety and health information and experienced scientists to ensure that those conducting the risk assessment have sufficient expertise. The following SDS Sections will be helpful in determining potential safety chemical hazards: 1, 2, 3, 6, 9, 10, and 11.
(b) Risk Assessment. Evaluate the hazards posed by the chemicals and the experimental conditions and the resulting health and safety risks they present. The evaluation should cover toxic, physical, reactive, flammable, explosive, radiation, and biological hazards, as well as any other potential hazards posed by the chemicals. For a variety of physical and chemical reasons, reaction scale-ups pose special risks that merit additional prior review and precautions. The following SDS Sections will be helpful in determining potential safety chemical hazards: 1, 2, 3, 6, 9, 10, and 11.
(c) Safety Action. Select appropriate controls to minimize health and safety risks resulting from exposure to potential hazards, including use of engineering controls, administrative controls, and PPE to protect workers from hazards. The controls must ensure that OSHA’s PELs are not exceeded. One should be prepared for contingencies and be aware of the institutional procedures in the event of emergencies and accidents. The following SDS Sections will be helpful in determining potential safety chemical hazards: 4, 5, 6, 7, 8, 11, 12, 13, 14, and 15.
The teacher should work with the administration and designated Chemical Hygiene Officer or safety officer to develop, review, and approve Job Hazard Analysis and Standard Operating Procedures detailing all aspects of work activities that involve hazardous materials. Additionally, make sure to include securing and using SDSs for each hazardous chemical being considered in hands-on laboratory investigations or and demonstrations. Lastly, be certain to provide guidance with PPE selection based on the findings in the job hazard analysis and the SDS.
NSTA Chief Safety Blogger Dr. Ken Roy wishes to sincerely thank Brian C. Duffy, Ph.D., a nationally recognized Wayne Community College chemistry instructor, NSTA Research in Science Education Committee member, and former NSTA Safety Advisory Board Chair for his professional review of this commentary.
Submit questions regarding safety to Ken Roy at firstname.lastname@example.org. Follow Ken Roy on Twitter: @drroysafersci.
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