The HCS 2012 requires chemical manufacturers, distributors, or importers to provide Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) for each hazardous
chemical to downstream users to communicate information on these hazards. SDSs are required to be presented in a consistent user-friendly, 16-section format. We will discuss this format
in this module.
The SDS includes information such as:
the properties of each chemical;
the physical, health, and environmental health hazards;
protective measures; and
safety precautions for handling, storing, and transporting the chemical.
The information contained in the SDS must be in English (although it may be in other languages as well). OSHA requires that SDS preparers provide specific minimum information as detailed
in Appendix D of 29 CFR 1910.1200. The SDS preparers may also include additional
information in various section(s). Employers must ensure that SDSs are readily accessible to employees.
Check out this short audio clip by Dan Clark of the theSafetyBrief.com that asks five important questions
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1. The Safety Data Sheet (SDS) describes all of the following, except _____.
a. the properties of each chemical
b. the physical, health, and environmental health hazards
c. protective measures
d. the union representing the employee
The HCS 2012 requires new SDSs to be in a uniform format, and include the section numbers, the headings, and associated information under the headings below:
Section 1: Identification - This section identifies the chemical on the SDS as well as the recommended uses. It also provides the essential contact information of the supplier.
The required information consists of:
Product identifier used on the label and any other common names or synonyms by which the substance is known.
Name, address, phone number of the manufacturer, importer, or other responsible party, and emergency phone number.
Recommended use of the chemical (e.g., a brief description of what it actually does, such as flame retardant) and any restrictions on use (including recommendations given by the supplier).
Section 2: Hazard(s) Identification - This section identifies the hazards of the chemical presented on the SDS and the appropriate warning information associated with those hazards.
The required information consists of:
hazard classification of the chemical (e.g., flammable liquid, category 1)
signal word, pictograms
hazard statement(s), precautionary statement(s)
description of any hazards not otherwise classified
Section 3: Composition/Information on Ingredients - This section identifies the ingredient(s) contained in the product indicated on the SDS, including impurities and
stabilizing additives. This section includes information on substances, mixtures, and all chemicals where a trade secret is claimed. The required information consists of:
Substances - Chemical name; Common name and synonyms; Chemical Abstracts Service (CAS) number and other unique identifiers; Impurities and stabilizing additives, which are
themselves classified and which contribute to the classification of the chemical.
Mixtures - Same information required for substances; chemical name and concentration (i.e., exact percentage) of all ingredients which are classified as health hazards and
are present above their cut-off/concentration limits or a health risk below the cut-off/concentration limits. The concentration (exact percentages) of each ingredient.
Chemicals where a trade secret is claimed - A statement that the specific chemical identity and/or exact percentage (concentration) of composition has been withheld as a
trade secret is required.
Section 4: First-Aid Measures - This section describes the initial care that should be given by untrained responders to an individual who has been exposed to the chemical. The required information consists of:
necessary first-aid instructions by relevant routes of exposure (inhalation, skin and eye contact, and ingestion)
description of the most important symptoms or effects, and any symptoms that are acute or delayed
recommendations for immediate medical care and special treatment needed, when necessary
2. Which SDS section would display signal words and pictograms?
a. Section 1: Identification
b. Section 2: Hazard(s) Identification
c. Section 3: Composition/Information on Ingredients
d. Section 4: First-Aid Measures
The SDS should describe fire-fighting response recommendations.
Section 5: Fire-Fighting Measures - This section provides recommendations for fighting a fire caused by the chemical. The required information consists of:
Recommendations of suitable extinguishing equipment, and information about extinguishing equipment that is not appropriate for a particular situation.
Advice on specific hazards that develop from the chemical during the fire, such as any hazardous combustion products created when the chemical burns.
Recommendations on special protective equipment or precautions for firefighters.
Section 6: Accidental Release Measures - This section provides recommendations on the appropriate response to spills, leaks, or releases, including containment and
cleanup practices to prevent or minimize exposure to people, properties, or the environment. The required information may consist of recommendations for:
Use of personal precautions and protective equipment to prevent the contamination of skin, eyes, and clothing.
Emergency procedures, including instructions for evacuations, consulting experts when needed, and appropriate protective clothing.
Methods and materials used for containment.
Section 7: Handling and Storage - This section provides guidance on the safe handling practices and conditions for safe storage of chemicals. The required information
Precautions for safe handling, including recommendations for handling incompatible chemicals, minimizing the release of the chemical into the environment, and providing advice on
general hygiene practices.
Recommendations on the conditions for safe storage, including any incompatibilities. Provide advice on specific storage requirements (e.g., ventilation requirements).
Section 8: Exposure Controls/Personal Protection - This section indicates the exposure limits, engineering controls, and personal protective measures that can be used to
minimize worker exposure. The required information consists of:
OSHA Permissible Exposure Limits (PELs), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs), and any other exposure limits
appropriate engineering controls
recommendations for personal protective measures to prevent illness or injury from exposure to chemicals, such as personal protective equipment (PPE)
any special requirements for PPE, protective clothing or respirators
3. Which SDS section includes containment and cleanup practices to prevent or minimize exposure to people, properties, or the environment?
a. Section 5: Fire-Fighting Measures
b. Section 6: Accidental Release Measures
c. Section 7: Handling and Storage
d. Section 8: Exposure Controls/Personal Protection
The SDS must describe the properties of classified chemicals on site.
Section 9: Physical and Chemical Properties - This section identifies physical and chemical properties associated with the substance or mixture. The minimum required information
Appearance (physical state, color etc.)
Upper/Lower flammability or explosive units
Initial boiling point & boiling range
Flammability (solid, gas)
Partition coefficient: noctonol/water
Section 10: Stability and Reactivity - This section describes the reactivity hazards of the chemical and the chemical stability information. This section is broken into three
parts: reactivity, chemical stability, and other. The required information consists of:
Reactivity - Description of the specific test data for the chemical(s).
Chemical stability - Indication of whether the chemical is stable or unstable under normal temperature and conditions. Description of any stabilizers. Indication of any safety
issues should the product change in physical appearance.
Other - Indication of the possibility of hazardous reactions and conditions under which hazardous reactions may occur. List of all conditions that should be avoided. List of
all classes of incompatible materials. List of any known or anticipated hazardous decomposition products.
Section 11: Toxicological Information - This section identifies toxicological and health effects information or indicates that such data are not available. The required
information consists of:
Information on the likely routes of exposure. The SDS should indicate if the information is unknown.
Description of the delayed, immediate, or chronic effects from short- and long-term exposure.
The numerical measures of toxicity - the estimated amount of a substance expected to kill 50% of test animals in a single dose (LD50).
Description of the symptoms. This description includes the symptoms associated with exposure to the chemical including symptoms from the lowest to the most severe exposure.
Indication of whether the chemical is a potential carcinogen.
Sections 12-15 - Note: Since other Agencies regulate this information, OSHA does not enforce Sections 12 through 15.
Section 16: Other Information - This section indicates when the SDS was prepared or when the last known revision was made. The SDS may also state where the changes have been
made to the previous version. You may wish to contact the supplier for an explanation of the changes. Other useful information also may be included here.
4. In which section of the SDS would you find a description of the delayed, immediate, or chronic effects from short- and long-term exposure?
a. Section 9: Physical and Chemical Properties
b. Section 10: Stability and Reactivity
c. Section 11: Toxicological Information
d. Section 16: Other Information
Manufacturers must prepare SDSs for chemicals they manufacture.
Below are some more important requirements manufacturers, importers and distributors must meet:
The manufacturer or importer must:
Prepare one SDS that applies to all similar mixtures where complex mixtures have similar hazards and contents (i.e. the chemical ingredients are essentially the same, but the specific composition
varies from mixture to mixture).
Ensure that the SDS information recorded accurately reflects the scientific evidence used in making the hazard classification.
Add new information to the SDS within six months after becoming aware of any significant new information regarding the hazards of a chemical, or ways to protect against the hazards.
If the chemical is not currently being produced or imported, add any new information to the material SDS before the chemical is introduced into the workplace again.
Provide an appropriate SDS with the initial shipment, with the first shipment after a SDS is updated, and as requested by the employer or distributor.
Retail distributors selling hazardous chemicals to employers having a commercial account must:
provide a SDS to such employers upon request, and
post a sign or otherwise inform them that a SDS is available.
5. How soon must manufacturers add new information to an SDS after becoming aware of any significant new information regarding the hazards of a chemical, or ways to protect against the hazards?
a. Within 30 days
b. Within six months
d. As soon as possible
SDSs may be kept at the primary workplace facility, as long as the employer can ensure quick access to this information.
Employers must obtain a SDS from the chemical manufacturer or importer as soon as possible if the SDS is not provided with a shipment that has been labeled as a hazardous
Employers must maintain SDSs in their workplace and must ensure that they are readily accessible during each work shift to employees when they are in their
Electronic access and other alternatives to maintaining paper copies of the SDS are permitted as long as no barriers to immediate employee access in each workplace are created by such options.
Make sure employees know how to quickly access SDS information that is stored on computers or online.
Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the SDSs may be kept at the primary workplace
facility. In this situation, the employer must ensure that employees can immediately obtain the required information in an emergency.
Employees who work at more than one site during the work shift must be able to obtain SDS information immediately (within seconds) in an emergency.
SDSs may be kept at the primary workplace facility, as long as the employer has a representative available at all times to ensure ready access (within a few minutes) to this
information. This is the only situation in which an employer is allowed to transmit hazard information via voice communication. The employer must address in the written hazard communication plan
how SDS information will be conveyed to remote worksites.
SDSs may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to
address the hazards of a process rather than individual hazardous chemicals.
6. Where must SDSs be maintained during each workshift?
a. Where unauthorized persons cannot have access
b. In a locked cabinet to protect the data
c. In a centralized office area at each worksite
d. Where they are readily accessible in work areas
The employer must educate and train exposed employees on classified workplace chemicals.
Employees must receive information and training that ensures their awareness of the chemical hazards used in their work area.
Employers must provide this information when an employee is initially assigned to a work area where hazardous chemicals are
present and before assignments involving new exposure situations.
Employees must be informed of:
the requirements of the HCS 2012
any operations in their work area where hazardous chemicals are present
the location and availability of the written hazard communication program (including the required list(s) of hazardous chemicals and SDSs required by the HCS)
To make sure all training requirements are met, we recommend reviewing each section of the SDS. Group discussion and examples can be effective training strategies to make the training more
interesting to students. Demonstrating and practicing the use of PPE for properly using and cleaning up spills is especially important.
Check out this short audio clip by Dan Clark of the theSafetyBrief.com that discusses a nine-step process to evaluate whether to clean up a chemical spill or evacuate.
7. To be most effective, safety data sheet (SDS) training should _____.
a. be completed within two weeks of employment
b. be conducted one-on-one
c. consist of primarily instructor lecture
d. include demonstration and practice
Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available
through labels and SDSs.
Napo in...Danger: Chemicals!
Employee training must include at least:
Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area.
The physical hazard, health hazards, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in
the work area.
The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from
exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace
labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.
8. Hazard communication training must include specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals.
The host employer must train the HCS on multi-employer worksites.
The training requirements also apply if the employer becomes aware via the multi-employer worksite provision of exposures of his/her employees to hazards for which they have not been
Training Temporary Employees
Training temporary employees is a responsibility that is shared between the host employer and temporary agency.
Host Employer: The host employer is responsible for training on the company's HCS program requirements including specific labeling, chemical hazards and safe
work procedures in their workplace.
Temporary Agency: The temporary agency, in turn, maintains a continuing relationship with its employees and would be expected to inform employees of the general
requirements of the HCS standard.
Contracts between the temporary agency and the host-employer should be examined to determine if they clearly set out the training responsibilities of both parties, in order to ensure
the employers have complied with all requirements of the regulation.
9. Who is responsible for training specific requirements of the company's hazard communication program to temporary employees?
a. The temporary agency
b. The host employer
c. A third-party contractor
d. Either the employer or temporary agency
Employees must know how to handle hazardous chemicals safely.
Training for Emergencies
A frequently overlooked portion of the training provisions is dealing with emergency procedures. In workplaces where there is a potential for emergencies, the employer's HCS training
program would have to address the HAZWOPER emergency response plan and/or emergency action plan.
The scope and extent of employee training regarding emergency procedures will depend upon the employer's Emergency Response Plan (ERP).
If the employer merely intends to evacuate the work area, the training in emergency procedures could be limited to, information on the emergency alarm system in use at the
worksite, evacuation routes, and reporting areas as detailed in the employer's emergency action plan under
1910.38, Emergency Action Plans.
10. If employees are expected to evacuate in response to a chemical spill or fire, which emergency plan would be activated?
a. Emergency action plan
b. Emergency operations plan
c. Fire response plan
d. Emergency evacuation plan
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