Published: November 2002
Department of Labour
Guide Completing Material Safety Data Sheets
Chief Directorate of Occupational Health and Safety
CONTENTS INTRODUCTION REGULATORY REQUIREMENTS FORMAT GENERAL ASPECTS DETAILS REQUIRED EXAMPLE MSDS
APPENDIX
1 2 3 4
Disclosure of ingredients Definition of toxicity Establishing the generic name Division of substances into families and subfamilies
We hereby acknowledge the assistance provided by the Chemical and Allied Industries’ Association for the Department of Labour
1 INTRODUCTION A material safety data sheet is a means of transferring essential information on the hazards of handling a chemical substance during transport, storage and processing from the supplier to the handler. It may also be used to transfer this information to institutions, services and other bodies that play a role in dealing with the chemical substances. Hazardous chemical substances should not be handled unless the handler has obtained the appropriate information. In terms of regulations promulgated under the Occupational Health and Safety Act (Act No. 85 of 1993) (R1449 of 6 September 1996; Government Notice No. 17403) it is compulsory for the supplier of any hazardous chemical substance to provide a material safety data sheet to any party which receives such a substance. In order to facilitate transfer of information and to establish uniformity, specific requirements as to how the information is to be given are set out in the regulation. The purpose of these Guidelines is to assist suppliers in the completion of the relevant material safety data sheet. REGULATORY REQUIREMENTS The relevant clause of Regulation 1449 of 6 September 1996 is set out below: 7 (1) Subject to the provisions of section 10(3) of the Act, every person who manufactures, imports, sells of supplies any hazardous chemical substance for use at work, must as far as is reasonably practicable provide the party receiving such substance, free of charge with a material safety data sheet in the form of Annexure 1, containing all the information as contemplated in either ISO 11014 or ANSI Z.400.1-1993.
Provided that where it is not reasonably practicable to provide a material safety data sheet, the manufacturer, importer, seller or supplier must supply the receiver of any hazardous chemical substance with sufficient information to enable the user to take the necessary measures as regards the protection of health and safety. (2) (3) Every employer must be in possession of a copy of the relevant Annexure 1 or a copy of sufficient information as contemplated in subregulation 1 for any hazardous chemical substance for use at work. Every employer must make the relevant Annexure 1 or sufficient information as contemplated in subregulation 2, available at the request of any interested or affected person.
2 FORMAT The MSDS must be written in the 16 Section Format citing the ISO 11014 or ANSI Z.400.1-1993 standards. Failure to comply with these regulations can result in a fine or imprisonment of both. The 16-section format is also found in other country’s standards such as: • UK Chemical Hazard Information and Packaging for Supply Regulations • EU Safety Data Sheet Directive (91/115/EEC, as amended by 93/112/EC) • Australian NOHSC:2011(1994) The 16 sections are always in the same sequence. Once the framework is known it is possible to go directly to the information required. This makes MSDSs from different companies and countries easier to read and understand. Whilst there are 16 sections, the MSDS is organized around only 4 key issues that address what needs to be known about chemicals, namely: • • • • What is the product and what should be known immediately in an emergency? What should be done if a hazardous situation occurs? How can hazardous situations be prevented from occurring? Is there any other useful information?
These 4 key issues can be expanded into the 16 sections that comprise a MSDS. • What is the product and what should be known immediately in an emergency? • Section 1 : Chemical product and company identification • Section 2 : Composition/information on ingredients • Section 3 : Hazardous identification What should be done if a hazardous situation occurs? • Section 4 : First-Aid measures • Section 5 : Fire-fighting measure • Section 6 : Accidental release measures How can hazardous situations be prevented from occurring? • Section 7 : Handling and storage • Section 8 : Exposure controls/personal protection • Section 9 : Physical and chemical properties • Section 10 : Stability and reactivity
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Is there any other useful information? • Section 11 : Toxicological information • Section 12 : Ecological information • Section 13 : Disposal considerations • Section 14 : Transport information • Section 15 : Regulatory information • Section 16: Other information, e.g. Label requirements, NFPA classification, references, etc. GENERAL ASPECTS
Every page must include the name of the chemical substance as used on the label, and must be dated and numbered. The page numbering system must include the total number of pages or must indicate the last page as such. The date indicated must be the latest revision date. The section must be separated clearly. The headings and subheadings must be presented in a conspicuous way. Text must be written in a clear and concise manner. Commonly used phrases are recommended and language must be acceptable to the recipient. DETAILS REQUIRED 1. Chemical product and company identification This section must state the product name as used on the label, the supplier product code and whether the chemical product is a substance or a preparation. In the case of a substance, the common chemical name must be given. Synonyms, if any, and the Chemical Abstract Service Registry Number (CAS number) must be given. This section must also state the name, address and telephone number of the supplier. The emergency telephone number used by the company must be given. Telex number, telefax number and e-mail address may also be given. 2. Composition / information on ingredients Ingredients contributing to the hazard must be indicated. In the case of a preparation, information about the chemical nature of the product must be given. It is not necessary to give the full composition. When defined, components contributing to the hazard or impurities contributing to the hazard of the preparation must be given, with their chemical or generic name and their concentration or concentration range. The classification and hazard labeling of these components or impurities may be given. References must be made to the classification system used. Appendix 1 provides an approach to disclosure of ingredients. 4 3. Hazards identification
This section must clearly and briefly summarize the most important hazards and effects of the product (adverse human health effects, environmental affects, physical and chemical hazards and, where appropriate, specific hazards). 4. First-Aid measures This section must state the first-aid measures to be taken, if necessary. If appropriate, it must state which actions have to be avoided at all costs. The information must be readily understandable by the victim and/or first aider. The information must be subdivided according to the different exposure routes i.e. inhalation, skin contact, eye contact and ingestion. 5. Fire fighting measures This section must state which extinguishing media are suitable and subsequently, if appropriate, which extinguishing media are NOT suitable. Specific hazards with regard to fire-fighting measures, specific methods of fire-fighting and special equipment for the protection of fire-fighters must be indicated here. 6. Accidental release measures This section must contain information on: • • • personal precautions environmental precautions methods for cleaning up (recovery, neutralization).
This information should include prevention of secondary hazards.
5 7. Handling and storage
Handling This subsection must describe appropriate technical measures (prevention of user exposure, prevention of fire and explosion and precautions for safe handling of the chemical product such as local and general ventilation and measures to prevent aerosol and dust generation). It must contain specific safe handling advice such as avoidance of contact with incompatible materials. Storage This subsection must describe appropriate technical measures and storage conditions (suitable, to be avoided) for safe storage of the chemical product, including separation from incompatible products. It must, in particular, contain information in respect of safe packaging materials (recommended, not suitable). 8. Exposure controls/personal protection If appropriate, engineering measures to reduce exposure must be given in this section. This information must be complementing that already given under heading 7 above. Specific control parameters such as limit values or biological standards with they’re, preferably dated, references, must be indicated. Information on the recommended monitoring procedures with their references must be given. This section must also contain recommendations on appropriate personal protective equipment such as for: • • • • respiratory protection hand protection eye protection skin and body protection
The kind of protection must be mentioned, including specific suitable material.
6 Some products only become hazardous when present in large amounts or high concentrations, or at elevated temperature or pressure. If appropriate, special precautions for these cases must be stated here.
If necessary, specific hygiene measures must be indicated. 9. Physical and chemical properties This section must include chemical product information and appearance, i.e. physical state, form and colour and on odour. Where applicable, this section must state information on: • • • • • • • • • • • pH, with indication of the concentration; specific temperatures/temperature range at which changes in physical state occur, e.g. Boiling point/boiling range. decomposition temperature flashpoint autoignition temperature explosion properties vapour pressure vapour density density solubility, with indication of the solvent(s) octagonal/water partition coefficient
Other data relevant to the safe use of the chemical product, such as radioactivity or bulk density, must be indicated as well. If appropriate, the method used in the determination of a property must be identified.
7 10. Stability and reactivity
This reaction must state the stability of the chemical product and possible hazardous reactions occurring under specific conditions. This heading must contain information on: • • • conditions to avoid materials to avoid hazardous decomposition products which may reasonably be expected, in addition to the carbon monoxide (CO), carbon dioxide (CO2) and water (H2O) normally formed.
Consideration must be given to intended use and reasonably foreseeable misuse of the product. 11. Toxicological information This section must contain a concise but complete and comprehensive description of the various toxicological (health) effects of the chemical product which can arise if the user comes into contact with the chemical product, including acute toxicity, local effects, sensitization and chronic toxicity or long term toxicity. If appropriate, distinction must be made between effects due to single exposure, repeating exposure and continuous exposure. If appropriate, immediate and delayed effects must be mentioned separately. The possible effects must also include, if appropriate, specific effects, e.g. carcinogenicity, mutagenicity and reproduction toxicity. Information must be given according to the different exposure routes e.g. inhalation, skin contact, eye contact, ingestion. Additional results or data from scientific experiments, with a reference to the source of information, may be given. Appendix 2 provides definition to toxicity.
8 12. Ecological information
This section must contain information on possible environmental effects, behaviour and fate, such as information on: • • • • mobility persistence / degradability bioaccumulation expected behaviour of the product in the environment/possible environmental impact/exotoxocity
Additional results or data from scientific experiments, with a reference to the source of information, may be given. Any ecological limit value may be indicated here. 13. Disposal considerations This section must contain appropriate information on recommended methods for safe
and environmentally preferred disposal.
These methods of disposal apply not only to the chemical product (waste from residues) but also to any contaminated packaging. Attention of the recipient must be drawn to the possible existence of local disposal regulations. 14. Transport information This section must contain information on codes and classifications according to international regulations for transport, differentiated by the mode of transport such as: • • • land (railway/road, such as RID1)/ADR2)/DoT 49 CFR3)) sea (IMDG Code4) air (ICAO-TI5), IATA-DGR6)
9 1) RID = Regulations concerning the international carriage of dangerous goods by rail.
2) 3) 4) 5) 6)
ADR = European agreement concerning the international carriage of dangerous goods by road. DoT 49 CFR = US Department of Transportation 49 Code of Federal Regulations. IMDG Code = International Maritime Dangerous Goods Code. ICAO-TI = International Civil Aviation Organization – Technical Instructions. IATA-DGR = International Air Transport Association – Dangerous Goods Regulations. The UN classification number must be stated. Additional regulations may be mentioned. Specific precautionary transport measures and conditions must be mentioned.
15.
Regulatory information This section must contain information on regulations specifically applicable to the chemical product. Hazard and safety information as written on the label must be indicated under this heading. Attention of the recipient must be drawn to the possible existence of local regulations.
16.
Other information This section must provide any further information, which may be important from a safety point of view but not specifically relevant to previous headings. For instance, special training needs and the recommended use and possible restrictions of the chemical product may be stated.
10 APPENDIX 1 DISCLOSURE OF INGREDIENTS
In most cases, there should be full public disclosure of ingredients. However, under certain conditions, non-disclosure of genuine commercially confidential information about ingredient identity may be permitted, subject to the following provisions. 1. Ingredients for which full disclosure is required Type I ingredients Full disclosure will always be required for some ingredients. Manufacturers or importers shall disclose on the MSDS for a hazardous substance the chemical name of any ingredient which: (a) in accordance with the ACGIH, NIOSH, EPA, OSHA, EU, NFP etc, is carcinogenic, mutagenic, teratogenic, a skin or respiratory sensitiser, very corrosive, corrosive, toxic or very toxic, a harmful substance which can cause irreversible effects after acute exposure, or a harmful substance which can cause serious damage to health after repeated or prolonged exposure; or has an exposure standard listed in the OHSA, ACGIH, OSHA is present in a quantity, which exceeds the lowest relevant concentration cutoff level specified for the hazard classification.
(b) (c)
A claim of commercial confidentiality cannot be made in relation to any ingredient, which meets these criteria. Generic names are not permitted for any of the above Type I ingredients. Where an ingredient meets the criteria of the above, but does not exceed the relevant concentration cut-off level, it is regarded as a Type III ingredient. 2. Ingredients for which generic names may be used Type II ingredients The manufacturer or importer may use a generic name on the MSDS, in place of the chemical name of an ingredient, if: (a) the ingredient is a harmful substance (b) is present in a quantity, which exceeds the lowest relevant concentration cut-off level. The generic names used should describe the functionality of the ingredient, which contributes to the hazard. (See attached Appendix 3, establishing the Generic Name).
11 3. Disclosure requirements for other substances
Type III Ingredients If an ingredient is not a Type I or Type II ingredient, then the chemical name need not be included by the manufacturer or importer in the MSDS. Instead, a generic name for the ingredient, as precise as is reasonably possible, should be used, for example, “organofluoride”. When use of a generic name provides inadequate commercial protection, and the ingredient is not a hazardous substance e.g. water PPG (propylene glycol), the ingredient need not be disclosed. Where the Type III ingredient is not a hazardous substance, but has known synergistic effects, at least a generic name must be used to identify it. 4. Disclosure of commercially confidential information Where the chemical identity of an ingredient has not been disclosed on the MSDS, it will be necessary to include on the MSDS the name and contact details where further information on the confidential information can be provided. The manufacturer has an obligation to disclose the chemical identity of an ingredient in specific emergency and non-emergency situations. 5. Emergency disclosure of information to medical practitioners The chemical name shall be disclosed forthwith to a medical practitioner who determines that a medical emergency exists and requests the information for the purpose of providing proper emergency or first-aid treatment. 6. Formulation confidentiality If the exact amount/concentration of an ingredient in the formulation cannot be specified, then the proportion ranges of each ingredient contained in the product should be indicated so as to provide as much information as possible about the potential hazards of a formulation. The following proportion changes are recommended: E.g. >60%, 30–60%, 10-30%, <10%
12 APPENDIX 2 DEFINITION OF TOXICITY
1.
VERY TOXIC:- (T+) R28:- Very toxic is swallowed, acute toxicity results: LD50 Oral, Rat <25 mg/kg Less than 100% survival at 5-mg/kg oral, rat, by the fixed dose procedure. R27: - Very toxic in contact with skin: LD50 Dermal, Rat or Rabbit: < 50mg/kg R26: - Very toxic by inhalation, acute toxicity results: LC50 inhalation, rat, for gases and vapours: <0.5 mg/litre/4hr LC50 inhalation, rat, for aerosols or particulates: <0.25 mg/litre/4hr
2.
TOXIC:- (T) R25:- Toxic if swallowed, acute toxicity results : LD50 Oral, Rat: 25