OSHA SDSs, aka the Occupational Safety and Health Administration mandated safety data sheets. Originally, OSHA SDSs were known as ‘Material Safety Data Sheets (MSDS)’ as addressed in the 1994 HCS legislation but the 2012 GHS-aligned revision of HCS (HCS 2012) leaves out the ‘Material’ part. It is not simply just removing the M though, rather the OSHA SDS update imparts a change in format and content requirements, and depending on which system was previously in place, these changes are not all that different! For HCS 1994, OSHA established a set of guidelines pertaining to the previous 8-sectioned MSDS format, but it was not authoritatively implemented into federal standards, leading to variant versions from suppliers of chemical products. The American National Standards Institute (ANSI) acted on behalf of the United States in efforts to collaborate with the International Organization for Standardization in which they also put-fourth guidelines (ANSI standard Z400.1-1993), but it corresponded to a 16-sectioned MSDS format; this format being more concurrent with GHS. The format of OSHA SDSs under the revised HCS 2012 took into account the benefits of using the ANSI-internationally aligned standards, thus from June 1st 2016 and on, the only accepted format is that of GHS-HazCom 2012.
Manufacturers and distributors are responsible for developing SDS sheets along with labels for any hazardous chemical products they synthesize or import. It is in the hands of employers: to adequately train all employees to recognize and understand the informational elements presented on the new HCS 2012 OSHA SDSs; to provide an efficient and easily accessible means of attaining safety data sheets, as hardcopies or electronically; and to inform employees about significant updates, upon receiving updated SDSs from manufacturers or importers. Accurate and thoroughly detailed information on the safety data sheets of hazardous products used in the workplace is fundamental to competent worker-safety protection programs. Previous studies conducted by OSHA and other governing bodies brought to light the incomprehensibility of (M)SDS sheets to the everyday worker, “When experts were asked whether MSDS were too complicated for workers to understand, 92% said that they were. This reflects the opinion that the information is too technical, too complicated and too poorly organized to be useful to workers” (Metzgar, 2009, p. 26-27). SDSs provide necessary information about chemical hazards and protective procedures, but they are not specifically tailored only for use in the workplace; health care professionals, laboratory technicians, emergency responders, and etc. all comprise the diverse audience that may be seeking technical information about chemical substances through safety data sheets. It is precisely for these reasons that GHS incorporation into HCS 2012 and the standardizing of the OSHA SDS format, makes sense.
Ultimately, OSHA’S decision of revising the United States’ hazard communication program in alignment with GHS, benefits all those whom are confronted with handling hazardous chemical products on a daily basis. The information most important to workers or users of these chemical products can be found in sections 1-8; presenting info about the product identity, chemical make-up, associated hazards, safe-handling practices, first-aid measures, and emergency procedures within the first few sections enables users to locate it rapidly. Sections 9-11, and 16, are more technically specific, presenting to readers all related scientific data including a products intrinsic chemical and physical properties, toxicological data, its stability and reactivity, and other jargon heavy content. No content is required under sections 12-15, but their headings are to still be included, so as to maintain uniformity of the OSHA SDS format with the GHS mandated format.