Material Safety Data Sheets MSDSs

With the adoption of GHS by OSHA, the problems associated with Material Safety Data Sheets (MSDSs) in many different formats will be solved. What other problems with MSDSs are likely to remain despite the standardized formatting?

Your response must be at least 400 words in length.

The creation of the new Global Harmonized System was perhaps the best global approach to minimize employee injuries in the workplace due to improper handling of chemicals. Although the Global Harmonized System was adopted by the United Nations in 2003, and OSHA attempting to align its regulations with the new GHS in 2009 (OSHA, n.d.), there are still some issues that could remain related to the Safety Data Sheets, even after the implementation of the GHS.

In studies conducted in 2008, it was found that in many products tested there were chemicals that did not have a current SDS or the information in the SDS was incorrect or missing. According to ChemHat.Org (n.d.) “Accuracy and completeness were found to be relatively poor, with the majority of studies presenting evidence that the MSDSs under review did not contain information on all the chemicals present, including those known to be serious sensitizers or carcinogens”. Even though these studies were conducted years ago, there still indications that SDSs are still missing pertinent information and some chemicals have non-existing SDS.

The monetary burden taken by the companies in regards to educating the workforce about the new GHS and the revised SDS can be a problem, even though proper employee training should have been completed by Dec 2013, there are perhaps millions of workers in the United States that are not aware of the Global Harmonized System changes. “A monumental education process for suppliers and users will soon be forthcoming, as parts of the GHS are adopted. Such adoption will also put heavy burdens on the consensus standards organizations to modify their standards to reflect such global changes in Hazard Communication” (Haight, 2012).

Another problem that could remain even after the GHS is fully implemented is the reclassification of chemicals. This process takes time and money, pushing manufacturers and importers to push their timelines in order to save money. Re-writing and updating MSDS into the new SDS is a burden to these companies, making this a significant problem likely to remain for some time. MSDSonline.com predicts this will be a problem in the future, “The problem is that chemical manufacturers and distributors are run by humans – and most humans are procrastinators. Also, for many manufacturers, re-writing all of the MSDSs into the new SDS format and sending them downstream is an expensive endeavor” (MSDSonline.com, 2013)

As of December 2013, all workers covered by the Occupational Safety and Health Administration were supposed to be trained on the changes of the MSDS into the new SDS. This is one of the many changes related to the adoption of the new GHS since it was created in 1992. This small-step-at-the-time approach can create issues for years to come; it gives companies the sense of a never-ending process. The “building blocks” approach is the process of integrating new parts of the GHS into the Hazard Communication Standard as new research is concluded, creating some sort of uncertainty to the process as to when is it going to complete (Haight, 2012).

References:

ChemHat.Org. (n.d.). What’s the Problem with MSDS?. How Material Safety Data Sheets Fall Short on Safety. Retrieved from: http://www.chemhat.org/en/for-workers/whats-problem-msds

Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. Des Plaines, IL: American Society of Safety Engineers.

Occupational Safety and Health Administration [OSHA].(n.d.).Foundation of Workplace Chemical Safety Programs. Retrieved from: https://www.osha.gov/dsg/hazcom/global.html

MSDSonline.com. (2013). From MSDS to SDS: 3 Reasons OSHA’s Transition to GHS is Going to Get Worse Before it Gets Better. Retrieved from: https://www.msdsonline.com/blog/compliance-education/2013/10/21/from-msds-to-sds-3-reasons-oshas-transition-to-ghs-is-going-to-get-worse-before-it-gets-better

Explain the differences between training, education, and instruction. How could the designer of a hazard communication program use all three of these learning concepts effectively?

Your response must be at least 400 words in length.

In order to best describe the main differences between training, education, and instruction, we must first determine what the program’s objectives are. Commonly used interchangeably, these terms are a bit different from one another, and they deliver a distinctive meaning (Stolovitch& Keeps, 2011). Determining the program’s objectives will help us decide the proper approach to teach our Hazard Communication Program.

For example, some of the differences between training and instructions are simple, training is conducted when the employee would be required to reproduce what he or she has been taught immediately, when we need employees to act automatically almost without thinking, or when we required workers to apply what they have learned the same way they were taught without deviations, regardless of the conditions (Stolovitch& Keeps, 2011). On the other hand, the instruction would denoteas to allow employees to think and act beyond what has been taught during class, and perhaps to adapt to new and unpredictable conditions.

Education refers to a long-term and wider implication of the learning process, according to Roger Buckley & Jim Caple (2009) “Education usually provides more theoretical and conceptual frameworks designed to stimulate an individual’s analytical and critical abilities”.

It becomes extremely important for a Safety Managers, or anyone designing a Hazard Communication Program to understand the differences between these three terms, as all three of them will accomplisha different objective. Some examples in the safety field about what education, training and instruction mean, take for example a Control Room Operator, someone that must observe pressure gauges and different reading instrument at any given time, this person must be educated to observe and interpret the reading and act accordingly to those reading and interpretations; this person is someone that understand the consequences of miss-readings or erroneously interpretation of the gauges. In Hazard Communication, education could be taken as understanding the consequences of poorly handled chemicals, spills, and releases (Wong, 2010). Training, on the other hand, can be seen as the physical ability to do a certain task, for example wearing the proper Personal Protective Equipment when using hazardous chemicals, this task is expected to be repeated every time the worker handle certain chemical. Training simulates the actual actions to be taken when the circumstances require.

Instruction may refer as to the effort from the employer to influence workers to think before they act; In Hazard communication, an instruction could include reading the SDS prior to using a hazardous chemical, verify Permissible Exposure Limits, choosing the proper PPE. “Instruction teaches the learner not just the “what” but the “why” and the “how” points out that employees not only need to be taught how to do something safelybut how to apply the information to their actual jobs” (Haight, 2012).

References:

Buckley, R. and Caple, J. (2009).The Theory & Practice of Training, 6th Edition. Philadelphia, PA. Kogan Page.

Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. Des Plaines, IL: American Society of Safety Engineers.

Stolovich, H. D. & Keeps, E. J. (2011). Telling Ain’t Training. Updated, Expanded, and Enhanced. 2nd Edition: Alexandria, VA. ASTD Press.

Wong, W. (2010).The Risk Management of Safety and Dependability.A Guide for Directors, Managers and Engineers. Boca Raton, FL. CRC Press.