Reading MSDS
Material Safety Data Sheets (MSDS, will be referred to Safety Data Sheets, SDS, if Global Harmonized System is adopted) are a required to be maintained under the Hazard Communication standard (CFR29.1910.1200). While the intention of maintaining documented specific chemical hazard information is logical (essentially why MSDS are required), in practice the maintenance of MSDS is little more than a paperwork filing exercise. MSDS must be available for employees exposed to chemical hazards for the purpose of accessing additional information, however the only person that usually refers to an MSDS for information is someone responsible for safety management. This practical reality and the intent of regulatory requirements for communication of chemical hazard information brings into question if employees must be able to read and understand a MSDS as a requirement.
To answer the question of how adept employees must be at reading a MSDS, you first need to evaluate the actual information included on MSDS. The majority of a MSDS is boiler plate legal text. Unfortunately, much of the hazard and precautionary information on MSDS is boiler plate. For example, “A system of local and/or general exhaust is recommended to keep employee exposures as low as possible” or “Dispose of container and unused contents in accordance with federal, state and local requirements”. Manufacturers are reluctant to include specific safety recommendations and are also reluctant to exclude generic warnings even for very innocuous materials. Usually, the only material specific information on a MSDS is physical characteristics (such as specific gravity and boiling point) and testing data such as toxicology testing, if such testing has been completed. Even specific material component information can be misleading. Ranges are usually given for material composition, and since most chemicals have several different names, the names used for a material component can even be misleading and the CAS number used. I have seen the name Yellow Chromate used instead of Lead Chromate on paint MSDS because the manufacturer is concerned that as soon as the word Lead is seen, the paint will not be used (which it should not be used). Basically, without some general chemistry knowledge MSDS information can be misleading or unusable.
Most plant employees will not have general chemistry knowledge to help them use MSDS information effectively. Training on the specific details available in a MSDS will essentially be a waste of time and will usually only undermine your safety program by being “Another boring safety presentation about information that does not affect us on the floor.” This can serve as another example to employees that safety is about rules and not about what they actually do every day. The key to effective safety management is employee engagement in the safety process. Getting to involved in technical details (what the Safety Manager should worry about) without bringing it into day to day work decisions and processes can demonstrate to employees that safety is an office process, not a work process that extends to everything we do. To achieve an injury-free workplace, the safety process must be brought to the floor level and extend into every task performed. Therefore, training on the content of MSDS should be limited to information employees can find useful or interesting, and many of the details left in the hands of the Safety Manager.
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