A number of STC needed assistance with the Safety Data Sheets (SDS) and label requirements of the 2012 update of the Hazard Communications Standard (29 CFR 1910.1200).

For one client, STC used SDS authoring software to assist with updating a large number of existing MSDS. For others, STC used component Safety Data Sheets (SDS), process details provided by the client, and the hazard classification protocol to classify the materials based on their physical and health hazards. The creation of these SDS highlighted the one-step criterion based classification of materials that are classified as carcinogenic.  It also indicated the reasoning behind OSHA’s enforcement guidance dated February 9, 2015 which OSHA provides leniency on the compliance date of June 1, 2015 for manufacturers of mixtures who, after exercising “reasonable diligence and good faith to classify their chemical mixtures”, have not yet to received 2012 compliant SDS and/or labels from upstream suppliers.  In a number of cases, STC was unable to obtain GHS compliant SDS and instead used existing component MSDS and external data such as toxicology studies.

STC then used the hazard classification to generate GHS compliant labels for each material. In one case we worked with the client to update internal documents that reference the revised labels.

If you would like more information or assistance creating compliant Safety Data Sheets, contact Pam Walaski at (412) 347-6004 or by email: pwalaski@stcenv.com.