Chemical Labels and Material Safety Data Sheets(MSDS)

Miller Engineering Services

Chemical Labeling and Material Safety Data Sheets(MSDS)

Chemical Exposures - Early Publications

Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1975). Psychomotor and Neuromuscular Changes in Workers Exposed to Inorganic Mercury. Journal of the American Industrial Hygiene Association, October.
Miller, J.M. and Chaffin, D. (1973). Behavioral and Neurological Evaluation of Workers Exposed to Inorganic Mercury. (NIOSH Contract #5T01-0N00161-02).
Miller, J.M., Chaffin, D., Dinman, B., Smith, R. and Zontine, D. (1973). An Evaluation of the Effects of Chronic Mercury Exposures on EMG and Psychomotor Functions (Final Report, NIOSH Contract #5T01-0N00161-02).

Chemical Labeling Requirements

In recent years there has been an increasing interest in the labels and MSDS materials which are required to be provided under OSHA's 29CFR1910.1200 - Hazard Communication Standard. In particular, paragraph (f) Labels and Other Forms of Warnings requires "(1) ...each container of hazardous chemicals is to be labeled, tagged or marked with the following:

(i) Identity;
(ii) Appropriate hazard warnings;
(iii) Name and address of manufacturer...."

Additionally, ANSI Z129.1, the American National Standard for Hazardous Industrial Chemicals - Precautionary Labeling, provides recommendations for formats, colors, sizes, symbols, and wording for chemical labels. These aspects of a label are important in creating an effective warning that workers will heed.

We are able to evaluate the extent to which manufacturers, bulk repackagers, and distributors of chemicals have in fact adequately addressed the required "Appropriate hazard warnings." As most cases of this nature involve long histories of employee exposure, we typically track the scientific, medical, and corporate knowledge of the specific hazards of a given substance and compare this information with government regulatory requirements for labeling. Examples of substances we have constructed histories of are including asbestos, tobacco, vinyl chloride, and perchloroethylene.

Material Safety Data Sheet (MSDS) Requirements

Relative to OSHA's 29CFR1910.1200 (g) Material Safety Data Sheets, there are twelve different categories of items which are required to be included within the MSDS. Because there is no required format for satisfying these requirements, and the authors of the MSDS sheets are often not available, it has been necessary for us to develop a special technique to determine how each of these requirements is addressed for each chemical. The same technique will also reveal any of the requirements which have not been fully complied with.

Here are the twelve requirements that MSDS's must include:

(g)(2)(i): The identity used on the label...

(g)(2)(ii): Physical and chemical characteristics of the hazardous chemical(s)...

(g)(2)(iii): The physical hazards of the hazardous chemical including the potential for fire, explosion and reactivity;

(g)(2)(iv): The health hazards of the hazardous chemical including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical;

(g)(2)(v): The primary route(s) of entry;

(g)(2)(vi): ... The OSHA permissible exposure limit , ACGIH Threshold Limit Value, and any other exposure limit used or recommended...

(g)(2)(vii): listing of hazardous chemical relative to carcinogenicity

(g)(2)(viii): Any generally applicable precautions for safe handling and use which are known to the chemical manufacturer, importer or employer preparing the Material Safety Data Sheet, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks;

(g)(2)(ix): Any generally applicable control measures which are known to the chemical manufacturer, importer or employer preparing the Material Safety Data Sheet, such as appropriate engineering controls, work practices, or personal protective equipment

(g)(2)(x): Emergency and first aid procedures

(g)(2)(xi): The date of preparation of the MSDS or last change to it

(g)(2)(xii): The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the Material Safety Data Sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.

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11/13/00