A number of you have just recently received your first look at a Safety Data Sheet. I had promised my customers that the Globally Harmonized System (GHS) with Safety Data Sheets (SDS) would be an improvement over the old Material Safety Data Sheet (MSDS). The first reports I received were that their reports ranged from 8 to 13 pages per SDS. That is considerably more than the old two page Material Safety Data Sheet. So, what the heck is going on here?

  I based my initial opinion on the number of required steps required for the SDS compared to those OSHA required for the MSDS. A lot of the required information is subjective. For example, you can write First Aid measures into a couple of paragraphs or you could write more exhaustively and end up with two pages of First Aid measures. I suspect that there is a lot of exhaustive writing in an 8 page SDS.

  As to why I can only speculate. It is a new requirement and manufacturers would rather be safe and certain they meet the minimum SDS requirements. In the case of the MSDS, the manufacturer had to satisfy one standard and mostly one agency, OSHA. The SDS requirements are written by the United Nations. GHS is a system, not a regulation. The system so far has been adopted by 65 countries and the goal is to have every country adopt it. If manufacturers are uncertain as to how much clarification each country will require, they will naturally tend to over-write with the hope of satisfying countries that are even more demanding than the United States.

  Given time, I think the SDS will atrophy and become about the same size as the typical MSDS. That may take a few years. Beyond that, there is a lot more to GHS than the SDS. The labels are definitely going to be better and more informative than what we had with the initial Hazard Communications Standard.

  Under the SDS, only the first 12 steps are mandatory. The last four are not. What if the distributor or manufacturer elects to cover the non-mandatory steps, is the consumer required to keep those parts of the SDS? If not, that might be a way to shrink it. I would hold off on that for the time being. In the meantime, you might want to shop for a much larger SDS binder. At 13 pages per SDS, one hundred products morph into 1300 pages. Someday in the not so distant future, this will all be digital and the length of the SDS will be insignificant. Hopefully, that day is soon.