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MATERIAL SAFETY DATA SHEETS

Workers in modern industrial workplaces are exposed to myriad toxic chemicals. In an effort to inform employees and persons in the community about the risks of toxic chemicals in the workplace, OSHA requires that employers make material safety data sheets (MSDS) available to employees, health care providers, local fire departments, and other community organizations with an interest in toxic exposures. (See Lerman and Kipen 1990 for a detailed discussion of MSDS.)[218]

MSDSs are the starting point for determining if an employee has been exposed to a toxic substance. Occupational medicine physicians should obtain appropriate MSDSs from each employer for whom they provide occupational medical services. MSDSs can also be useful for general medicine physicians who suspect that a patient is suffering from an occupational exposure.

Each material safety data sheet shall be in English and shall contain at least the following information:

--The identity used on the label, and, except as provided for ... trade secrets;

--If the hazardous chemical is a single substance, its chemical and common name(s);

--If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common name(s) of the ingredients which contribute to these known hazards, and the common name(s) of the mixture itself; or,

--If the hazardous chemical is a mixture which has not been tested as a whole:

--The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition, except that chemicals identified as carcinogens under paragraph (d)(4) of this section shall be listed if the concentrations are 0.1% or greater; and,

--The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise less than 1% (0.1%) for carcinogens) of the mixture, if there is evidence that the ingredient(s) could be released from the mixture in concentrations which would exceed an established OSHA permissible exposure limit or American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value, or could present a health hazard to employees; and,

--The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical;

--The primary route(s) of entry;

--Emergency and first aid procedures;

--The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.

There are several important limitations that may make the data on MSDS misleading. Within certain limitations, the manufacturer is not required to perform toxicity testing on the mixture or its constituents. The MSDS need only be based on a review of the literature. Even this review is subject to question because there are no standards to define an adequate search or to resolve conflicting research reports. It is not unusual to find manufacturers of the same chemical with different health risks on their MSDS. In addition, manufacturers sometimes ignore chemicals that they use as vehicles but do not manufacture themselves. While these are generically described as inert ingredients, they sometimes include highly toxic aromatic hydrocarbons or complex organic resins.

If the MSDS does not provide enough information, either because trade secret information has been left out or because the physician suspects that an ingredient is toxic, the physician can obtain more detailed information directly from the manufacturer identified on the MSDS. This may require several inquiries, however; only the original manufacturer of the substance is responsible for keeping full information on health hazards. Thus the physician may need to call the manufacturer of each substance that has been mixed into a product.

1196(1991).

[218]Lerman SE; Kipen HM: Material safety data sheets: Caveat emptor. Arch Intern Med 1990; 150:981-84.

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