Signs of a poorly written SDS

Chemscape and their authoring business Deerfoot Consulting place a great value on the quality of the SDSs that we produce. There are many options for Safety Data Sheet authoring on the market. Here are some red flags we see when examining SDSs written by low-cost providers and automated authoring programs. The results are poorly written SDSs that do not conform to GHS standards, provide inaccurate information and can even be non-compliant.

Red Flag #1: An inexperienced and untrained SDS Author

Does your SDS Author have proper training, experience and credentials? Deerfoot uses a Registered SDS Author, registered since 2013, which is the premier standard for this work.

Red Flag #2: The structure, presentation and required elements of the SDS does not conform to GHS Standards 

With the implementation of GHS there is greater structure than there used to be in WHMIS 1988.  Chemscape frequently observes short comings in the classification, presentation of required elements in and structure of the document.

Red Flag #3: Use of inaccurate hazard classification 

This is a bit alarming but sometimes incorrect symbols can be used with the classifications the author has listed.

Red Flag #4 Omission of precautionary statements

Chemscape developed a reference document which consolidated the official GHS Purple Book.  https://www.chemscape.com/media/3422/ghs-classification-hp-statements_v2.pdf  This reference document clearly identifies classifications (not how to classify but what statements that must be included after classification.  I will use codes of Precautionary Statements from the link in my comments.  There is some latitude regarding Precautionary Statements based on professional opinion but to entirely exclude Statements these is wrong.

Red Flag #5: No Signal Word or Improper Placement

The signal word (Danger or Warning) needs to be displayed for the product as required according to the WHMIS Act and Regulation.

Red Flag #6 No contact information for author

A reputable author will put their business name and valid contact number on the SDS. If the SDS is ever used as evidence in a court of law the author may be required to testify and provide records to justify their classification and sampling data.

Red Flag #7 The old MSDS was simply retitled as an SDS

Yes, it is true and Bonnie in our data entry department attests to having seen companies swap out the old 9-section MSDS with a new title that says Safety Data Sheet but no other changes have been made other than a new issue date.

How Safety Data Sheets differ significantly between countries

A common question Chemscape is asked regarding the transition to GHS and WHMIS 2015 is whether only one SDS is now required. Does one SDS work now for all countries since it is a Globally Harmonized System(GHS).

Although the GHS has introduced standardized communication for Labels and Safety Data Sheets, countries have adopted these standards into their own legislation, and SDSs still vary significantly by country. A variance can result in a different classification, labelling, SDS or other information requirements for a hazardous product in Canada versus another like the USA. An experienced SDS author can help you navigate the constantly changing classification and regulatory landscape.

  1. Although we have common GHS standards there is no harmonization between countries. The Globally Harmonized System was created by the United Nations. It is currently in Revision 7. It is up to individual countries to adopt what revision they want. There are differences in GHS requirements by country. The GHS was created with a building block approach and this allows countries to adopt the standards into their jurisdictions as best suits them. Every country decides what revision to implement. For example, currently the USA uses revision 3 and Canada uses revision 5. These leads to a lack of harmonization between countries.
  2. Every country has unique regulations for transportation and the environment. On top of GHS standards every country has local regulations like transportation or environmental regulations that are unique and need to be integrated into Safety Data Sheet authoring.
  3. Local regulations and classifications keep changing. If you pay attention to TDG in Canada particularly since the Lac Megantic tragedy you will be aware of how these standards are not static and require someone to keep up-to-date with regulatory changes.
  4. Classification of substances vary between countries. As there are different revisions of the GHS being adopted by different countries we see substances classified differently between jurisdictions.
  5. Toxicity data is ever changing. Research is constantly evolving with new data being published daily on the effects of toxicity of certain substances on humans, animals, and the environment.
  6. Exposure scenarios can be difficult to predict. The SDS author often needs to work with the client to predict possible exposure scenarios. Data can often be absent.
  7. Exposure cut-offs can vary between countries. What may be considered acceptable in one country may have greater restrictions in another.
  8. Ingredients can be allowed for commerce in one country and not in another. In Canada the Domestic Substance List contains approximately 23, 000 substances approved for commercial use, import and manufacture.
  9. Concentration ranges for ingredients can be used differently in different countries.
  10. Confidential Business information is withheld in the client’s best interest and there are different methods to do this according to country location.

For all the above reasons, SDSs still differ significantly between countries. SDSs should still be updated on a routine basis to ensure current data is available. In BC, Saskatchewan and the Territories their provincial WHMIS 2015 laws require the employer to check every 3-years if any significant data have changed. For suppliers, the SDSs must be accurate at the time of sale or import, for each sale or import. It is a requirement to update the SDS when significant new information becomes available.

Simultaneous Operations “SimOps” and Identifying Health Hazards

Do you have Concurrent or Simultaneous Operations in your organization? Could one operator’s tasks be unknowingly generating health hazards for others? Learn how to quickly Identify, Communicate and Control Chemical Hazards and Health Risk at these job sites. Our safety expert John Artym and Industrial Hygienist Mike Phibbs CIH ROH face off.

At many jobsites there are multiple operations occurring at the same time. Imagine welding, abrasive blasting and coating all taking place at the same location at the same time. The execution of two or more tasks by two or more functional groups on the same location at the same time are referred to as Simultaneous or Concurrent Operations “SimOps”.

Being effective at ensuring health and safety at the workplace requires commitment (from management and workers), resources, and a mature Health and Safety Management System. This challenge increases in complexity on a jobsite with SimOps or Concurrent Operations. We will define Simultaneous or Concurrent Operations “SimOps” as the execution of two or more tasks by two or more functional group activities on the same location at the same time. You are more likely to find SimOps during construction or when major maintenance work is being done within a “live” process area of an existing facility, on multiple well pad operations and multiple contractor facilities.

Safety View on SimOps Hazard Management Industrial Hygienist View on SimOps Hazard Management
During SimOps, organizations must consider how the hazards can be transferred or released to other functional groups.

Think of an example in construction or fabrication:  Equipment is being manufactured and/or fabricated at a jobsite where several hazardous chemicals are being used or created (i.e. welding fumes, toxic paints, abrasive blasting). Does your Chemical Management system or SimOps plan account for the electrical crew working downwind from the sand blasting operations? Are the painters working alongside the welders aware of the hazard and potential occupational health harms of the welding fumes?

The concern is that while performing independent operations, these activities and/or events may impact the health and safety of personnel or equipment or the environment of another operation. Specifically, with respect to Chemical Management and preventing exposure to workers both the physical and occupational health risks must be managed. First, to control the chemical hazards during SimOps a thorough hazard assessment should analyze each chemical and its ingredients. It is important to KNOW the Hazard. Secondly, the risk needs to be determined based on utilization (quantity, volumes, time, volatility), the task being performed and the effectiveness of the controls and measures. Who is in control of the chemical? Remember to include all your Manufactured Products, Process Additives or Shop Supplies.

Key Considerations:

1.      Do you have systems in place to maintain the Chemical Inventory, complete the hazard ranking/grouping and can communicate the hazards and controls/measures?

2.      Consider the task being performed. Will workers encounter those chemicals or their by-products? Has the physical state changed (e.g. bentonite with crystalline silica in a solid state mixed into a liquid solution)? Has the risk changed?

3.      Are the engineering controls changing (e.g. hazardous product is contained in a piping system, but containment must be broken to change filters or take samples)?

4.      Is there an energy source that will transfer the hazardous chemical or harms into concurrent operations (e.g. failure of a pressurized system spreads liquids containing BTEX across the jobsite)?

5.      Do the administrative controls and measures, PPE/RPE requirements apply for all the crews/workers on the jobsite? Consider who is at risk.

6.      Success is based on concise and on-going communication. Do your systems and “plan” demand expectations? When SimOps are planned or identified, it is important that all relevant and involved parties are include in the SimOps plan.

At multi-employer work sites with multiple hazards Industrial Hygienist need to focus on identifying and communicating the health hazards and risks in these situations. For example, on a job site you may have abrasive blasting, welding and coating tasks all taking place at the same time. We often focus on the individual tasks and hazards and focus on controlling the hazard for that task and the individual(s) involved. But on a busy job site there is typically numerous activities going on. Employers must protect their workers for the sum of the hazards on the job site regardless of who introduces a hazard. Chemical hazards do not respect fence posts or boundaries between tasks and when you add in the factor of wind these individual health hazards interact and pose additional health hazards.

In this common situation the hazards and risk need to be quickly determined. Controls need to be determined. Which party will determine what is acceptable? Who will implement? Who will bear the costs? How will this be communicated at the job site so others will act?

There are two professional trains of thought among the IH community and let’s call them System 1 vs. System 2 thinking. System 1 is automated – control first and then monitor. System 2 is calculated – monitor and then control. Health hazards lend themselves to System 1. IH’s commonly adhere to System 2. But daily exposure for workers need immediate action. Operations don’t cease for measurement, study and recommendations for exposure reduction that can take weeks to conclude.

Risks are not controlled if your hazards are not known. This returns to the foundation of doing a thorough hazard inventory. Being aware of all known health hazards. Having a discussion on how hazards transfer across workspaces. Will one operator’s tasks generate health hazards for others? Do controls for one work space apply to all?

Have you decided who is ”Prime” or how many “Primes” are at the site? The Prime Contractor on a jobsite is obligated to protect workers. But what if there are multiple primes on a jobsite? Is everyone in agreement?

It is important to define physical and task boundaries. Do Minimum PPE and Administrative Controls apply universally? Do Engineering Controls cause interactions? i.e. LEV vents towards others. Do controls change with the task?

Simplified and clear communication is important in this situation. Who is responsible to communicate the information to certain groups and in what level of detail? Icons and Images are effective to communicate information quickly and reach audiences who may have language and literacy challenges.

 

The quicker you identify hazards, understand potential interactions and communicate concisely the more effective you will be at preventing harm from chemical exposure(s) during Simultaneous Operations or Concurrent Operations. Commitment and communication from the project Owner, the Prime Contractor(s), and Contractors on the site is critical to effective management the numerous challenges encountered on a SimOps work site.

Chemicals and Medications contribute to Hearing Loss

March 3rd was World Hearing Day. It is well known that exposure to noise levels in the workplace can cause hearing loss.  However, you may not be aware that exposure to certain chemicals in the workplace as well as medication you may take on a regular basis can also damage your hearing.  These chemicals are said to be ototoxic (oto = ear, toxic = poisonous).  Furthermore, work activities where noise and ototoxin exposure are combined can lead to even more severe damage. There are over 750 groups of chemicals that are potentially ototoxic.  Some chemicals in your workplace may include benzene, carbon monoxide, lead, mercury, carbon disulfide, styrene and toluene. Exposure to ototoxins in the workplace can occur through swallowing, skin contact/absorption or inhalation. System administrators can use the msdsBinders system to identify chemicals that contain a least one ingredient that is known as an ototoxin.

Ototoxic medications have a toxic effect on the nerve cells of your inner ears. Over time, long-term usage of certain prescription medications can result in tinnitus or hearing loss. Hearing loss caused by an ototoxic medicine tends to develop rapidly. Initial symptoms tend to be ringing in the ears (tinnitus) and vertigo.  Hearing usually returns to normal after the patient stops taking the medicine. But some medicines can cause permanent damage to the inner ear and this results in permanent hearing loss.

A common prescription drug that can be ototoxic is Viagra. A 2007 study, published in The Archives of Otolaryngology-Head and Neck Surgery, shows that some individuals who have taken Viagra and other PDE-5 inhibitors reported sudden hearing loss in one or both ears, sometimes accompanied by tinnitus, or a ringing in the ear. In fact, men who have taken Viagra or other PDE-5 inhibitors are twice as likely to report hearing loss than men who have never taken the little blue pill. The findings prompted the Federal Drug Administration to send out a new warning for Viagra in 2007. The reason for the reported hearing loss isn’t specified, though hearing experts believe that increased blood flow to the delicate hearing mechanism may damage parts of the auditory (hearing) system.

Other commonly used medicines that may cause hearing loss which may surprise you include: Aspirin, when large doses (8 to 12 pills a day) are taken; Acetaminophen; and Anti-inflammatory drugs NSAIDS, like ibuprofen and naproxen. A study published in the March 2010 issue of The American Journal of Medicine suggests that regular use of these pain relief medications can cause hearing loss. The study, conducted by scientists at Harvard University, Brigham and Women’s Hospital, Vanderbilt University and the Massachusetts Eye and Ear Infirmary found an increased risk of hearing loss in men younger than 60 who regularly used NSAIDs.

Other commonly used medicines that may cause hearing loss include: certain antibiotics like aminoglycosides; diuretics; and certain chemotherapy drugs.

2018 Initiatives for WorkSafeBC in Oil and Gas

On November 29, 2017 WorkSafeBC presented a Pre-Drilling Season Update in Ft St John. Chemscape attended and I wanted to share some key points from this meeting. The Upstream Oil and Gas Industry in BC currently has 1,891 employers. Oil and Gas has the lowest injury rate of all classification Business Units in BC but they have one of the highest short term disability duration. Tragically, there has been 13 work-related deaths in the past 5 years.

A main message from WorkSafeBC was that exposure to hazardous chemicals remains a major risk for workers. Although injuries are down year over year drilling related work remains the highest risk for injury. Inspection reports and prevention orders have been increasing year over year.  In 2018, 95 Targeted Inspections occurred – 25 Occupational Exposure focused inspections.

In 2018, WorkSafeBC has an initiative in Oil and Gas to reduce the serious injury and fatality rate by implementing risk reduction tactics. WorkSafeBC predicts occupational disease claims and deaths to surpass the rates of injuries in the upcoming years.

Exposure Control Plan’s will continue to be a compliance focus for them in 2018 in Oil and Gas with a risk assessment of potential hazardous exposures including hydrocarbon based drilling fluids, aromatic hydrocarbons (benzene, toluene etc.), NORMS, Silica (new asbestos), Diesel exhaust. There are emerging concerns on welding fumes migrating through respiratory system/circulatory system and lodging in major organs as well as Ultra Violet Rays from the Sun as 1 in 3 new cancer diagnoses in Canada is now a skin cancer.

Some other Field issues which were addressed in the meeting include:

  • Proper respirator use and fit testing, being clean shaven. (OHSR 8.40(1-2)
  • Annual Hearing testing of workers (OHSR 7.8)
  • Immediate Reporting of Reportable Incidents
  • Having adequate Confined Space Entry Procedures: ability to identify all confined spaces by a Qualified Person; ability to conduct a proper hazard assessment of the CS’s by a Qualified Person; Failure to develop proper CSE prior to entry by a QP; Proper testing and monitoring of the atmosphere in the CS (before and during entry); Adequate continuous ventilation of the confined space, Proper supervision of confined space entry, adequate training of workers, Supervisors and persons conducting the CS assessments; and having ECP’s for hazardous products in the CS.
  • Tank cleaning safety concerns: having adequate grounding and bonding, adequately monitoring for hazardous atmospheres during cleaning, Vac trucks being equipped with rated hoses, valves and fittings; adequate training of all involved workers in regards to hazard assessments, proper SWP, use of equipment; having an ECP for exposure monitoring; having proper or appropriate PPE; disclosing and monitoring tank cleaning by parties commissioning the work.
  • Issues related to recent fire & explosion at well site due to vapor overflow at de-gasser.

Contact us at marketing@chemscape.com if you are interested in receiving the full report with all the field issues and concerns which WorkSafeBC encouraged all attendees at the meeting to share with their network.

A chemical management system can help address many of these issues. If you are challenged with this or developing Exposure Control Plans Chemscape can help.

Managing the upcoming changes to Alberta Occupational Health and Safety Act

By: John Artym, Vice President of CHAMP

As you are probably aware the Alberta Occupational Health and Safety Act is currently being reviewed, proposed changes have been shared for comment and Bill 30 has received first reading in the Legislative Assembly. Putting aside the legislative process for review and approval, it is important that organizations, managers, and workers all take the required time to assess the changes, identify any gaps in their Health and Safety Management Systems and consider strategies for implementation.

Understanding the “Why” for the proposed changes may help your teams determine/assess your gaps and develop your Corrective Action Plans.

Things to Consider: Do you have adequate authorities, responsibilities and accountabilities? How effective are your management systems? How engaged is your workforce? What are you measuring?

Some of the key areas being reviewed include:

  1. Responsibilities of Work Site Parties.
    1. How do you define “Health and Safety”? Do you consider psychological and social wellbeing? What about “Fit for Duty”, preventing violence or harassment at the worksite?
    2. How do you define worksites and who are your supervisors of the said worksites?
    3. Are your Supervisors competent?
  2. Health and Safety Program or Management systems.
    1. How are you engaging your workers? How do you communicate the hazards at your worksites? Do you have a Joint Work Site Health and Safety Committee?
    2. How are you planning to implement the Right to Refuse Dangerous Work? What actions are required when you shift from the “obligation” to the “right”?
  3. Reporting of incidents and OH&S responses.
    1. What type of incidents must be reported? What are the changes to the thresholds for reporting (hospital Admissions vs.2-day requirement or potential to cause a serious injury)? Who needs to be involved in the investigation?
    2. Additionally, the WCB Act has numerous proposed changes: Workers and Employers Code of Rights, establishment of an Occupational Diseases and Injury Advisory Committee, etc.

Ultimately the proposed changes are about preventing Occupational illness/diseases and injuries. The challenge for organizations is how to successfully implement.

For more information on this topic I personally recommend visiting these links:
http://www.assembly.ab.ca/ISYS/LADDAR_files/docs/bills/bill/legislature_29/session_3/20170302_bill-030.pdf

https://www.alberta.ca/ohs-changes.aspx#top

https://www.bennettjones.com/en/Publications-Section/Updates/Dramatic-Revision-of-the-Alberta-Occupational-Health-and-Safety-Act

Health & Safety Apps for working with Chemical Hazards

Here are some Health and Safety apps for working with Chemical Hazards that we have been recommending to make your work more productive:

Wiser
WISER (Wireless Information System for Emergency Responders) is a mobile application designed to assist first responders in hazardous material incidents. The WISER application extracts content from TOXNET’s Hazardous Substances Data Bank (HSDB), an authoritative, peer-reviewed information resource maintained by the National Library of Medicine. It provides accurate information about hazardous substances, the emergency resources available, and the surrounding environmental conditions to save lives and minimize the impact on the environment and physical property.
Android
https://play.google.com/store/apps/details?id=gov.nih.nlm.wiser&hl=en
Apple
https://itunes.apple.com/ca/app/wiser-for-ios/id375185381?mt=8

ERG App
PHMSA (U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration)’s 2016 Emergency Response Guidebook provides first responders with a go-to resource to help deal with hazmat accidents during the critical first 30 minutes.
Apple
https://itunes.apple.com/ca/app/erg-2016/id592158838?mt=8
Android
https://play.google.com/store/apps/details?id=gov.nih.nlm.erg2012&hl=en

msdsBinders
We have to recommend out own app! Search for your companies (M)SDSs, print, email and save your binder offline. You must be a customer with msdsBinders to use this. Free app available on apple and android devices.
Apple
https://itunes.apple.com/ca/app/msdsbinders/id982354626?mt=8
Android
https://play.google.com/store/apps/details?id=com.chemscape.msdsbinders&hl=en

NIOSH Pocket Guide to Chemical Hazards Mobile Web Application
This Mobile Web App works on any mobile device with an HTML5-compliant web browser and can be used offline. The industrial hygiene information found in this Pocket Guide assists users to recognize and control occupational chemical hazards. Content is sourced from the National Institute for Occupational Safety and Health (NIOSH®).
Apple
https://itunes.apple.com/us/app/chemical-hazards-pocket-guide/id337472634?mt=8
Download it from your web browser on your mobile device.
https://www.cdc.gov/niosh/npg/mobilepocketguide.html?s_cid=3ni7d2NiUpdatemNPG07142016