The Occupational Safety and Health Administration (OSHA) hazard notification standards detail how health care organizations should inform employees of any hazardous chemicals they may be exposed to at work. A key element of the standard involves Safety Data Sheets (SDS).

These information-rich documents are critical to ensuring the safety of workers, patients and the environment. The following section details OSHA’s SDS requirements and how organizations ensure consistent compliance.

What is a Safety Data Sheet (SDS)?
Safety data sheets convey comprehensive information about chemicals, including their characteristics; physical, health and environmental hazards; and any protective measures or safety precautions that should be followed when handling, storing or transporting materials.

OSHA requires chemical manufacturers to provide SDS to any entity that uses hazardous chemicals, such as medical facilities. In turn, health care organizations must ensure employees have quick access to the latest SDSs for hazardous chemicals used and stored in their workplaces. This standard emphasizes the importance of making SDS detailed and easy to understand. To this end, SDS follows a prescribed, user-friendly format.

What is the purpose of the safety data sheet?
Safety Data Sheets (SDS) are your compass in chemistry. Let’s break it down:

Purpose: SDS provides information on chemical-related hazards. They guide safe handling practices and emergency procedures.
Standardization: SDS follows Globally Harmonized System (GHS) standards for classifying chemical hazards.
Variability: Although standardized, SDS content may vary by manufacturer.
Legal requirements: Employers must obtain a safety data sheet (SDS) for hazardous substances and provide it to employees.
Training responsibilities: Principal Investigator (PI) and Lecturer conduct SDS training for laboratory personnel and maintain signed training records.

How many parts are in the safety data sheet and what information is contained?
The SDS is divided into 16 parts and conveys the following information:

Section 1: Identify chemicals by name, including any common abbreviations or synonyms; what the material can be used for; and emergency contact information for the supplier.
Section 2: summarizes the hazards of chemicals and warning messages. Manufacturers will use declarations and pictograms that comply with the requirements of the Globally Harmonized System, a set of internationally created and approved health, physical and environmental hazard classification standards.
Section 3: lists the ingredients of the product, including impurities and stabilizing additives.
Section 4: describes first aid measures such as primary care, acute and delayed symptoms, and any recommendations for broader medical treatment for individuals exposed to chemicals.
Section 5: outlines how to control fires caused by chemicals, including suitable fire-extinguishing equipment, possible hazards from fires, and any recommended personal protective equipment (PPE).
Section 6: describes how to respond to spills, leaks, or releases, including containment and cleanup measures to prevent or minimize exposure. Other topics include how to respond to leaks of varying sizes, appropriate safety precautions and emergency procedures.
Section 7: provides guidance on the handling and storage of chemicals, including any incompatibilities, ventilation requirements and hand hygiene recommendations.
Section 8: describes how to minimize worker exposure, describes exposure restrictions, potential engineering controls, and recommended personal protective measures.
Section 9: A range of relevant physical and chemical characteristics associated with the substance or mixture are identified, including but not limited to appearance, flammability, odor, solubility, flash point and viscosity.
Section 10: Overview of reactivity hazards and stability information for chemicals.
Section 11: details the toxicological and health effects, such as possible routes of exposure, effects of exposure, and whether the chemical is considered a carcinogen.
Section 12: provides information on the potential environmental impacts that chemicals may have after release into the environment.
Section 13: describes correct disposal practices, including whether materials can be recycled or recycled and whether this applies to containers for chemicals. Further information includes container instructions, appropriate disposal methods, and any special precautions for landfill and incineration. There is also strong language that discourages sewage treatment.
Section 14: Provides guidance on information on the transport and transport classification of hazardous chemicals.
Section 15: Providing information on safety, health and environmental regulations
Section 16: Provides additional information not included anywhere else in the SDS, including preparation dates and last revision dates.

Where should safety data sheets be kept?
Employers, including all types of health care organizations, must provide employees with immediate access to safety data sheets for hazardous chemicals in their workplace. There are many ways to promote access. For example, employers can save their SDSs in a binder, store them electronically, or work with a third party such as Stericycle to store them in the cloud.

OSHA is not prescriptive as long as employees have immediate access to information without leaving the work area. Even if an organization chooses to store the SDS electronically, there should be a backup in case of power outages or other emergencies.

Do household items require safety data sheets?
OSHA does not require SDS for household consumer products used in the workplace, provided that these products are used in accordance with the purpose, duration and frequency of use by the consumer.

If employees exceed this exposure level, safety data sheets are required.

Do employees exposed to hazardous chemicals need training?
Employees should receive training when they are first assigned to work with hazardous chemicals to ensure they understand the risks and practices that can keep themselves and their colleagues safe before starting to interact with materials. If they have not received training on the material so far, they should also receive training when introducing new hazardous chemicals into the work area.

Hazardous chemicals training requirements
Training must include more than just reading SDS. Appropriate education describes the hazards associated with chemicals in the work area, what measures can be taken to minimize risks, how to respond to leaks, and how this work relates to the overall hazard communication standard.

Training should be easy to obtain and understand. It should also include opportunities for employees to ask questions to ensure they fully understand the information provided.

Organizations can conduct training by hazard categories (such as carcinogens, sensitizers and highly toxic agents) so that staff can understand the relationship between chemicals and have a broader understanding of how to stay safe. As long as they fully meet OSHA requirements, they can also integrate SDS training into larger OSHA training.

How to ensure your organization complies with OSHA’s SDS requirements
The first step in complying with OSHA SDS requirements is to identify hazardous chemicals present on site in medical facilities. This may require an inventory of each room and listing all chemicals present.

Once the organization has a detailed list, staff can check that the required SDSs are available and accessible. Organizations may want to designate one or more specific people responsible for obtaining and maintaining SDS. If the required SDS is missing, the designated employee should ensure that the SDS is provided.

It is also important to check that the SDS is up to date. The manufacturer will send the SDS at the time of first delivery of the chemical or after a change to the document. When the new SDS arrives, staff must compare it to the existing SDS to determine what has changed. Organizations should have processes to broadly communicate any new information to employees.