OSHA—that favored child of the Department of Labor—requires that a safety data sheet (SDS) accompany various materials or products used in the workplace. Informed by the manufacturer, the SDS must contain information & instructions regarding the safe use and potential hazards associated with a chemical, compound, or mixture.
What’s in a name?
The SDS used to be called a material safety data sheet—aka an MSD. It was changed in 2012 when international standards were agreed upon—or “globally harmonized”. Prior to that, info & formats could differ within & across countries. BTY, some out-of-the-loop people call the document a PSDS, i.e. product safety data sheet. To each his own.
Regardless of the initialisms, the OSHA Hazard Communication Standard requires that a SDS be readily available to anyone & everyone in your workplace who has occasion to handle what the agency deems “a potentially hazardous substance,” which is a large and dynamic gallery of materials and products on EPA radar.
Also, to comply with the Emergency Planning and Community Right-to-Know Act, you must also make a SDS available to your local fire department in case of an unplanned incendiary event, as well as to your local & state emergency planning officials (see Section 331 if you’re eco-curious or have acute insomnia).
What info does the SDS contain?
The SDS presents data about a chemical, a compound, or a mixture across 16 headings in the following order:
- Hazard(s) identification
- Composition/information on ingredients
- First-aid measures
- Fire-fighting measures
- Accidental release measures
- Handling and Storage
- Exposure controls/personal protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information
- Other information
The OSHA Hazardous Communication Standard
The OSHA Hazard Communication Standard has four main requirements, first of which is (1) “a written hazard communication program” documenting how your company complies with the overall standard. It must also include a list of hazardous materials and how employees are informed of their presence and hazards thereto. The other three requirements are:
- Labeling. All hazardous chemical containers must be properly labeled, tagged, or marked with prominently displayed shipping labels. Info must be in English. If you’ve employees who speak something else, the label can contain that language, but the equivalent English must also be there.
- Safety data sheets. While you can have an electronic version available, you must keep a paper SDS for each hazardous material so that employees can access it ASAP should the power and/or internet go down—each a pregnant possibility in case of fire, explosion, or doing business in the State of California.
- Employee training. You must inform & train employees about all the hazardous of a material before assigning them to work with it. This includes where the SDS is kept for the hazardous material, where the hazardous material might be encountered in the workplace, and how to keep themselves safe & sound when they’re around it.
A word about hazardous waste disposal
You can bet that if some chemical, compound, or mixture is accompanied by a SDS, then any unused portion will require hazardous waste disposal. You just can’t dump it down the drain or into the storm sewer.
So what to do?
With smaller amounts—at the admitted risk of sounding trite—the best way of managing leftover hazardous materials is to not have any in the first place. I.e., procure only as much as you require so that it’s used up—and then how to dispose of it becomes a moot point.
Still…you’re probably going to have some left. One idea: give it away. Post it on Craig’s List or some other e-board under Free Stuff. Churches, theater groups, charities, or your local housing authority might be happy for small quantities of usable paint, cleaning products, etc.
But if you still have to get rid of it somehow, the next thing to do is check the SDS or product label for specific disposal instructions. E.g., if it’s a chemical that’s neutralized by water, you might be able to pour it safely down the drain with the faucet running.
Disposing of business, manufacturing, and industrial quantities
At the business, manufacturing, and industrial level: it’s crucial to get expert advice.
One of the oft-forgotten imperatives of the Resource Conservation and Recovery Act (RCRA) is that you’re responsible for any hazardous waste you “generate” from “cradle-to-grave.” This includes its generation, transportation, treatment, storage, and disposal.
Thereby, you’re not only accountable for a hazardous waste from the moment it’s generated; you’re also legally responsible for its safe transportation to wherever it will be ultimately processed or disposed of.
You’ll be culpable for any improper off site transportation and disposal—should such a thing happen—along with all the legal and financial liabilities thereto, not to mention the public relations nightmare that goes along with being labeled a “polluter.”
True, you might only generate a single quart of waste solute per week, but the improper disposal of even that small amount can land you squarely in the crosshairs of the EPA, which is not a good place to be.
It can be a fulltime job in itself to ensure that a hazardous-waste management vendor is properly licensed and adequately experienced to handle the kind and size of waste stream you generate.
This is especially true in that you’ll need more than one kind of vendor in order to comprehensively manage your hazardous-waste stream: transporters, storage sites, treatment facilities, etc.
As in all things involving the EPA—it’s crucial to get expert advice.
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