Visual Chemical Safety The Safety Data Sheet: In What Order Do You Review The Sections?
With the objective of teaching a non-technical worker how to review the SDS? And to figure out what to tell them about how to safely use the chemical?
We’ll use Bleach as our example for this post
As a professional: There will be LOTS of Safety Data Sheets for Bleach. Probably with a lot of variation in terms of how good the information is. We’ll do a whole blog post about the challenges of dates, getting an SDS for the correct manufacturer and product.
But for today, let’s assume this SDS is the correct manufacturer and is sufficiently current to use.
I’ll take a quick look at the first page, but it generally isn’t as informative or useful to me as some of the later pages.
If I have time, I’ll take a quick look at the whole data sheet then come back to the specific items of interest in the order suggested below. If pressed for time, I’ll go right to the sections that are most likely to be the most helpful
This is a better Safety Data Sheet than many, I can get some good info from the first page. After verifying the Product Name, and in this case I can check the Revision Date on the first page (sometimes it’s on the last page), this is what I get from this page
It has a UN Number (United Nations identification number). Means it’s sufficiently hazardous to be in the Emergency Response Guidebook (ERG)
It has an EPA Pesticide registration number (FIFRA number, Federal Insecticide Fungenticide Rodenticide Act) number. In some cases, the chemical has only the FIFRA number and provides no additional information regarding the chemical hazards. If that is the case, the worker is required by law to only use the chemical in accordance with the FIFRA information provided
a and b Both of these statements provide similar information about the hazards, that this chemical is corrosive to skin and eyes
Signal word. I’m only mentioning it because it’s on this page and easy to see, but I don’t find it particularly useful. What mnemonic do you use to teach workers the difference between the signal words? I use that Danger comes before Warning alphabetically
Next I go right to the Physical/Chemical Properties, Section 9 of the SDS, which in this case is on page 5
5 The pH is 11.8-12.4, which immediately tells us something useful. It happens to be consistent with the Hazard information we got on Page 1, but even if that hazard information was’nt provided (which is usually the case), the pH gives me instant actionable info
(How do you teach the pH values and their significance to workers? I use that a low pH is like the letter A for Acid which is Awful or Awfully Corrosive. Larger numbers are Later in the alphabet, so Basic or Caustic and also Corrosive)
6 The Specific Gravity is 1.1, which is consistent with what I would expect given the pH. Specific gravities less than 1, I’m looking for volatile components. Specific gravities greater than 1, I’m looking for concentrated acids or bases, or halogenated.
7 It also mentions Soluble in water, useful in the event of a spill
You’ll also notice a LOT of “No data available” and “None known”
8 Next I go right to the Transport Information, Section 14. A lot of times there will be no information here (and if there isn’t, ask yourself if that’s consistent with the information you have so far?). When there is a DOT Department of Transportation Basic Description, which is the combination of the Proper Shipping Name, Hazard Class, UN Number and Packing Group, it is sometimes the best and most specific information you will find on a data sheet.
In this case it tells us that this chemical as shipped (Limited quantity) is only a Packing Group III, which is the least hazardous of the packing groups.
9 Next I look at the Constituents , which are in Section 3, on Page 2 of this SDS. The information is consistent with what I would expect based on what we’ve seen so far.
For a lot of SDS’s, this section will say “Not regulated by OSHA” or “No hazardous ingredients”, which is why we looked at the other information provided before going to this section
Back to Section 2, Hazards Identification. Item 10, Pictograms The physical hazard pictograms are pretty useful, the health hazard ones less so. The Corrosive pictogram is what we would expect here (but since it can be fatal if swallowed why no skull and crossbones toxicity pictogram?)
The regulatory information may appear in different ways and different regulations may be shown
11 In many cases the regulatory information will have info that appears nowhere else on the SDS, especially with respect to constituents.
Now I’ll go back and review the detailed content (text) of the data sheet, but with the intention of asking “what is this like that we already use and for which we already have a set of Safe Use Instructions?”
And asking the corollary question “What is different about this chemical that causes it to need a new Safe Use Instruction or changes to an existing one?
Perhaps most importantly, I’ll be asking “what is missing or inconsistent or unclear” especially as it relates to teaching a worker how to use this chemical safely. There’s a huge glaring one for this SDS.
Let’s go back to Section 10, Stability and Reactivity
How many of our workers or students would get the picture of incompatibilities that the picture below conveys?
I could never remember what cleaning chemicals weren’t supposed to be mixed until I saw this cartoon…
While this picture doesn’t convey to the worker that it’s the chlorine in the bleach combining with the ammonia that gives off a toxic gas, but for this example it doesn’t matter. For the analogy of a chlorinated cleanser combining with the ammonia, you would need to convey that additional information somehow.
The next big question is:
What are we (still) missing?
to be able to know what we need to be able to keep the worker safe?
How about
How much will be used across what time frame (a few ounces once per shift or continuously for an 8 hour shift?
How will it be used (spray, wipe, diluted or not?
Will it be heated? What ventilation is available in the area(s) in which it will be used?
Community Outreach: How does this differ from how you review a Safety Data Sheet? What other information would you/ do you collect in order to assign a Safe Use Category to this type of use?
Until next time…
