One of the major changes that workplaces will see under OSHA’s new Hazcom 2012 regulations has to do with Material Safety Data Sheets. OSHA has decided to align their requirements with the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Safety Data Sheet (SDS) preparation requirements. What industry has historically called a Material Safety Data Sheet, or MSDS, will now be referred to as simply a Safety Data Sheet, or SDS.
Along with the new name, the SDS’s will have specific requirements for content. SDS’s under the Hazcom 2012 regulations are required to follow a 16 section format and include specific information in each section. The required sections are as follows:
Section 1, Identification
Includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
Section 2, Hazard(s) identification
Includes all hazards regarding the chemical; required label elements.
Section 3, Composition/information on ingredients
Includes information on chemical ingredients; trade secret claims.
Section 4, First-aid measures
Includes important symptoms/ effects, acute, delayed; required treatment.
Section 5, Fire-fighting measures
Lists suitable extinguishing techniques, equipment; chemical hazards from fire.
Section 6, Accidental release measures
Lists emergency procedures; protective equipment; proper methods of containment and cleanup.
Section 7, Handling and storage
Lists precautions for safe handling and storage, including incompatibilities.
On April 11, 2012, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice of proposed rulemaking (NPRM) in the US Federal Register relating to transportation of lithium batteries by air. PHMSA is considering harmonizing the current hazardous materials regulations (HMR) with the requirements that are found in the 2013-2014 ICAO Technical Instructions. PHMSA published an NPRM in January 2010 addressing harmonization to the 2011-2012 ICAO Technical Instructions, but a final rulemaking was not published in relation to that previous NPRM. The new NPRM will incorporate the additional or revised requirements found in the newer Technical Instructions, and will allow interested persons to supplement comments that were submitted previously. The lithium battery provisions recently adopted by ICAO will become effective for international air transport on January 1, 2013. Comments relating to this NPRM are due by May 11, 2012.
I admit it. I am a hazmat nerd. I’m not sure exactly when I realized it. Maybe it was the first time I recited a section of 49CFR from memory during a class. Maybe it was when I decided to keep a copy of the ERG in my car so I could identify the UN numbers on placarded trucks. Regardless of when it happened, I now embrace my hazmat nerdiness… even my Facebook profile lists my occupation as “Hazmat Nerd”. Obviously, this is a great benefit when I’m on the job. I have a knack for remembering obscure requirements and knowing where to find them in the appropriate regulation. I enjoy hunting down the answer to tough questions or unusual situations. I like having customers who think of me as their go-to source for their questions.
One aspect of being a hazmat nerd is that I am always noticing things that relate to my job, even when I’m not at work (hence the ERG in my glove compartment). There was the time that I was doing some geocaching (my obsession…I mean hobby) in Buffalo. I had parked the car and jumped out to go find a cache. On my way, I had to dodge some large puddles due to a recent downpour. As I approached one of the puddles, I noticed something odd. There was a Flammable Liquid placard floating in it! Most people would have just walked past it. Not the hazmat nerd! I took a closer look…mainly to see if it was one of our placards. Then I took a picture, because who wouldn’t want to see a picture of a placard in a puddle? I continued on my way, trying to figure out what circumstances would result in a placard floating in a puddle in the middle of a sidewalk. I still wonder about that…
Another time, I pulled up to a gas station and saw 2 IBC’s of paint sitting alongside the building. Once again, they would have gone unnoticed by most people. I however, took a picture!
On one of my many road trips, I made a stop for some fuel for both myself and my car at a truck stop. While walking around to stretch my legs, I came across something I had not seen before…a stop for leaking hazmat vehicles. It made sense that there would be such a thing and I’m wondering why I don’t see them more often in my travels. It’s good to know that drivers do have designated areas where they can go if there is leaking hazmat. Of course I had to take a picture… what kind of hazmat nerd would I be if I didn’t?
I always notice placards on trucks when I’m driving. I even notice empty placard holders on trucks, especially when there is a more than just one or two. Imagine my delight when I was driving behind a truck with eleven placard holders on the back of it! I couldn’t wait until we got to a red light so I could take a picture (not surprising by now, I’m sure). By the way, eleven is my current record for number of placard holders on a single side of a vehicle.
I could go on with my work related, off-the-job hazmat spotting, but I’ll stop here. I will continue to notice these things and have my camera at the ready to document them. And I am proud to say that I am a hazmat nerd!
I always cringe when someone asks me what I do for work. Not because I dislike my job (in fact, I’m one of the few people I know who truly enjoys their work) but because it’s so complicated to explain what I do! Sure, I could simply say I’m a Regulatory Specialist and let them stare at me blankly and try to figure out what that means, but they usually expect more of an explanation.
After going through the explanation for a new acquaintance yesterday, I got to thinking that many of our customers may not know exactly what ICC’s Regulatory Specialists do either. Some of my “regular” customers only deal with one aspect of my expertise, and are often surprised when they learn how many hats I really wear on a regular basis. After 8 years on the job, I have collected many responsibilities to keep me on my toes.
Training – One of the main duties of the Regulatory Specialist (RS) at ICC is to deliver training classes to our customers. For me, this includes the US 49CFR Hazmat regulations, the IATA Dangerous Goods Regulations and the IMDG Code. These classes can take place at our training centers, the customer’s facility, a hotel, or even via an online webinar. Not only do we conduct the training, but we also develop the presentations and quizzes that are used. We have to ensure that all of the information is accurate, up to date and gives the attendees enough information so that they can follow along and learn how to use the applicable regulations.
MSDS – Lately, my main focus has been related to our MSDS services. We provide expertise on MSDS reviews, reformatting and authoring for many areas of the world. Currently, I am able to complete work for the US and Canada but will hopefully be able to add the European Union to my knowledge base soon. With the impending OSHA Hazcom standard update to the Globally Harmonized System (GHS), I have been preparing myself for the changes that are going to take place. Writing an MSDS is no simple task, there is research involved, as well as interpretation of the information once it is found. There isn’t a simple “formula” that can be applied to spit out a finished MSDS. Sometimes it’s difficult to explain why a 6 page document can take several weeks to complete.
Help Desk – We pride ourselves on our customer service at ICC. One of the things that sets us apart from the competition is our regulatory help desk. If our customers have questions related to the regulations and how they apply to their products, they can call and speak to a regulatory specialist to set them straight. I have reviewed shipping documents, assisted in packaging selection, clarified requirements, spoken to carriers and provided help in countless other ways. Many customers that I have built relationships through the years love having the “phone a friend” option to fall back on when they get stuck, confused or completely lost with the regulations.
Internal Education – Just as our customers rely on our expertise, our coworkers come to us when they have questions. Whether it’s a customer relations associate who wants to know about a new label that we offer, our packaging specialist needing advice on a new design, or a business development manager who needs a unique solution for a customer, we get ideas and problems bounced off of us on a regular basis.
Product Development and Review – As regulations change, so do the products that we offer. The regulatory specialists are involved in ensuring that all new products meet the applicable regulations. In addition, when an existing product has to be reprinted or remanufactured, we perform a review to make sure that there are no regulatory changes necessary. We also review our existing products as the regulations change.
All of these tasks keep me busy and make every day at the office different. I have learned a lot since my first days at ICC, and there is still more to add. Even this list is not complete; there are always those miscellaneous requests and tasks that come across my desk. All in a day’s work for this regulatory specialist!
In January 2011, OSHA proposed that in August of this year, they would publish the final rule to align the current Hazard Communication Standard (HCS) with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The more recent DOL Spring semi-annual regulatory agenda released in June revisits the scheduling of the release of the HCS revision to an unspecified date in September of this year. September has now come and gone, and we are still without a final rule from OSHA.
This leads to the question of “If not now, then when?”. It is probably a safe assumption that OSHA’s lack of implementation of GHS to date will be a major topic of discussion at the October 1st – 5th Society for Chemical Hazard Communication (SCHC) fall conference in Washington, DC. Many health and safety professionals, myself included, will be impatiently waiting for word of a revised deadline.