MSDS and Label Preparation
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Your responsibility:
To make sure the hazardous chemicals are identified.
You must

WAC
296-839-20005
Conduct complete hazard evaluations.
IMPORTANT:
- Hazard evaluation is a process where hazards of chemicals
are identified by reviewing available research or testing information.
You aren’t required to perform your own laboratory research or
testing to meet the requirements of this section.
- - Information from hazard evaluations is used to
complete material safety data sheets (MSDSs) and labels
- - MSDSs from your suppliers may be used to complete
the hazard evaluation for chemicals you produce
- - MSDSs and labels are NOT required
for chemicals that are determined to be nonhazardous
- Importers and manufacturers are required to develop
MSDSs. If you choose to develop MSDSs for a product you don’t
import or manufacture, then this chapter also applies to you.
You must
(1) Describe in writing your
procedures for conducting hazard evaluations.
(2) Conduct a complete hazard evaluation for ALL chemicals
you produce or import to determine if they're hazardous chemicals.
- Identify and consider available
scientific evidence of health and physical hazards
- Evidence that meets the criteria
in Table 3 must be used to establish a hazard
- Chemicals identified in a Table
4 source must be regarded as hazardous
- The scope of health hazards
considered must include the categories in Tables 5 and 6
- If the chemical is a mixture,
follow the additional criteria in Table 7.
If you find evidence that meets the criteria in Table 3, use it in your
hazard evaluation.
Table 3
Criteria for Hazard Evidence
|
Hazard |
Criteria |
| |
- Where available, use human case reports of health
effects
and
- One or more studies that
– Are based on human populations,
if available, and animal populations
and
– Report statistically significant conclusions of a hazardous
effect or health hazard (as defined in this rule)
and
– Have been conducted following established scientific principles
Note:
- If human data isn't available, use results of
tests done on animals and other available studies to predict health
effects on employees (for example, effects resulting from short
and long-term exposures to chemicals).
- In vitro studies alone don't generally form
the basis of a finding of hazard.
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- Valid evidence that shows a chemical is any
one of the following as defined in WAC 296-839-500:
- – A combustible
liquid
- – A compressed gas
- – Explosive
- – Flammable
- – An organic peroxide
- – An oxidizer
- – Pyrophoric
- – Unstable (reactive)
- – Water-reactive
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Helpful Tool:
Information Resources for Preparing Material Safety
Data Sheets and Labels
In addition to Table 4, you may find this form
useful when conducting hazard evaluations. You can find a copy of
this form in the Resources Section of this book. |
You must
Chemicals identified in the sources listed in Table 4 must be
assumed to be hazardous (including carcinogens and potential carcinogens).
Table 4
Information Sources Indentifying Hazardous Chemicals
|
- Sources that address a broad range of hazard
categories:
- – Chapter 296-62 WAC, General Occupational
Health Standards, WISHA
- – 29 CFR Part 1910, Subpart Z, Toxic and
Hazardous Substances, Occupational Safety and Health Administration
(OSHA)
- – Threshold Limit Values for Chemical
Substances and Physical Agents in the Work Environment, American
Conference of Governmental Industrial Hygienists (ACGIH) (latest
edition).
- Sources that identify
carcinogens or potential carcinogens:
- – Chapter 296-62
WAC, General Occupational Health Standards, WISHA
- – 29 CFR Part 1910, Subpart Z, Toxic and
Hazardous Substances, Occupational Safety and Health Administration
(OSHA)
- – National Toxicology Program (NTP), Annual
Report on Carcinogens (latest edition)
- – International Agency for Research on
Cancer (IARC) Monographs (latest editions).
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Note:
The Registry of Toxic Effects of Chemical Substances
is published by the National Institute for Occupational Safety and
Health (NIOSH) space and identifies chemicals found to be potential
carcinogens by the NTP and IARC.
|
Chemicals meeting Table 5 definitions, along with the criteria for established
evidence in Table 3, must be regarded as hazardous.
Table 5 is NOT intended to present all hazard categories or test
methods. Available scientific data involving other test methods
and animal species must also be evaluated to determine a chemical's hazards.
Table 5
Standard Health Hazard Categories
|
A chemical is considered to be |
IF |
|
- The International Agency for Research on Cancer
(IARC) considers it to be a carcinogen or potential carcinogen
or
- The National Toxicity Program (NTP)(latest edition)
lists it as a carcinogen or potential carcinogen
or
- It's regulated
by WISHA or OSHA as a carcinogen
|
|
- It causes visible destruction of, or
irreversible alterations in, living tissue (not inanimate
surfaces) by chemical action at the site of contact
- Example:
– A chemical is corrosive if tested on the intact skin of
albino rabbits by a method described by the U.S. Department of
Transportation (in Appendix A to 49 CFR Part 173) and, it destroys
or changes (irreversibly) the structure of the tissue at the contact
site after a 4-hour exposure period.
|
|
- It has a median lethal dose (LD50) greater than
50 milligrams per kilogram, but no more than 500 milligrams per
kilogram of body weight, when administered orally to albino rats
weighing between 200 - 300 grams each.
or
- It has a median lethal dose (LD50) greater
than 200 milligrams per kilogram, but not more than 1000 milligrams
per kilogram, of body weight when administered by continuous contact
for 24-hours (or less if death occurs within 24-hours) with the
bare skin of albino rabbits weighing between 2-3 kilograms each
or
- It has a median lethal concentration (LC50),
in air:
- – Greater than 200 parts per million,
but not more than 2000 parts per million (by volume of gas or
vapor)
or
- - Greater than two milligrams per liter, but
not more than 20 milligrams per liter, of mist, fume, or dust,
when administered by continuous inhalation for one hour (or less
if death occurs within one hour) to albino rats, weighing between
200-300 grams each
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- It has a median lethal dose (LD50) of 50 milligrams,
or less, per kilogram of body weight when administered orally
to albino rats weighing between 200-300 grams each
or
- It has the median lethal dose (LD50) of 200
milligrams, or less, per kilogram of body weight when administered
by continuous contact for 24 hours (or less if death occurs within
24 hours with the bare skin of albino rabbits weighing between
2 to 3 kilograms each
or
- It has a median lethal concentration of (LC
50) and, in aiir, of:
- – 200 parts per million (by volume),
or less, of gas or vapor
or
- – 2 milligrams per liter, or less, of
mist, fume, or dust, when administered by continuous inhalation
for one hour (or less if death occurs within one hour) to albino
rats weighing between 200-300 grams each
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- It is NOT corrosive, but causes
a reversible inflammatory effect on living tissue by chemical
action at the contact site
Examples:
– The chemical is a skin irritant when
tested on the intact skin of albino rabbits (by the methods of
16 CFR 1500.41) for 4 hours exposure, (or by other appropriate
techniques) and the exposure results in an empirical score of
5 or more
– A chemical is an eye irritant if so determined
under the procedure listed in 16 CFR 1500.42 or other appropriate
techniques
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- It causes a substantial proportion of exposed
people or animals to develop an allergic reaction in normal tissue
after repeated exposure
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Categories provided in Table 6 illustrate the broad range of target organ
effects that must be considered when conducting hazard evaluations. Chemicals
meeting Table 6 definitions, along with the criteria for established evidence
in Table 3, must be regarded as hazardous.
Examples provided in Table 6 are NOT intended to be
a complete list.
Table 6
Examples of Target Organ Effect Categories Category
|
Category |
Definition |
Examples of Signs and Symptoms |
Examples of Chemicals |
Hepatotoxins |
Cause liver damage |
- Jaundice
- Liver enlargement
|
- Carbon tetrachloride
- Nitrosamines
|
Nephrotoxins |
Cause kidney damage |
|
- Halogenated hydrocarbons
- Cadmium
|
Neurotoxins |
Cause primary toxic effects on the nervous system |
- Narcosis
- Behavioral changes
- Decrease in motor functions
|
- Mercury
- Carbon disulfide
- Lead
|
Chemicals that act on the
- Blood
or
- Hematopoietic (blood forming) system
|
- Decrease hemoglobin function
or
- Deprive the body tissues of oxygen
|
- Cyanosis
- Loss of consciousness
|
- Carbon monoxide
- Cyanides
- Benzene
|
Chemicals that damage the lungs |
- Irritate lungs
or
- Damage pulmonary tissue
|
- Cough
- Tightness in chest
- Shortness of breath
|
|
Reproductive toxins |
Affect reproductive capabilities, including:
- Chromosomal damage (mutation)
- Effects on fetuses (teratogenesis)
|
|
- Lead
- 1,2-Dibromo-3-chloropropane (DBCP)
- Nitrous Oxide
|
Cutaneous (skin) hazards |
Affect the dermal layer of the body |
- Defatting of the skin
- Rashes
- Irritation
|
- Ketones
- Chlorinated compounds
|
Eye hazards |
Affect the eye or ability to see |
- Conjunctivitis
- Corneal damage
|
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Table 7
Criteria for Evaluating Chemical Mixtures |
If a mixture |
THEN |
- Has been thoroughly tested as a whole for physical
or health hazard
|
- You must use those results
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- Has not been tested as a whole
for a health hazard
|
- You must:
- – Evaluate EACH ingredient in the mixture
to determine the hazards
- – Consider the mixture to have the same
hazard as each ingredient determined to be hazardous
|
- Has not been tested as a whole
for physical hazards
|
- You must:
- – Use any scientifically valid data available
to evaluate the potential physical hazards of the mixture
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WAC
296-839-20010
Provide access to hazard evaluation procedures.
You must
- Provide access to your written
hazard evaluation procedures when requested by any of the following:
- – Employees
- – Designated representatives
of employees
- – Representatives of the
Department of Labor and Industries
- – Representatives of the
National Institute for Occupational Safety and Health (NIOSH).
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