Although Safety Data Sheets (SDSs) (formerly Material Safety Data Sheets or MSDSs)may seem complex, evaluating them for relevant information is not as complicated as it may first seem. An SDS should be read to the depth needed to make the required determinations such as if the product is hazardous; how to best store the product; what personal protective equipment (PPE) is required when using the product; and how to properly dispose of the product. The following are examples to clarify this point. Keep in mind that these are time-saving suggestions, and you may need to develop a different system if that works best for you and your practice.
Although MSDS formats differed among manufactures in the past, the minimum information each had to convey was standardized. The information contained in the SDS is largely the same as the MSDS, except the SDSs are required to be presented in a consistent user-friendly, 16-section format:
- Identification of the Product and Manufacturer
- Hazard(s) Identification
- Composition/Information on Ingredients
- First Aid Measures
- Fire Fighting Measures
- Accidental Release Measures
- Handling and Storage
- Exposure Controls / Personal Protection
- Physical and Chemical Properties
- Stability and Reactivity
- Toxicological Information
- Ecological Information (non-mandatory)
- Disposal Considerations (non-mandatory)
- Transport Information (non-mandatory)
- Regulatory Information (non-mandatory)
- Other Information
SDS "red flags"
There is a lot of information on an SDS, and it could be easy to miss vital pieces of information if you are not careful in your review. An established system for performing physical examinations of your patients helps prevent omissions and improves efficiency; similarly, developing a routine, systematic way of reviewing SDSs will be extremely helpful. You know the red flags associated with patient triage; the following are some key SDS red flags for products.
SDS red flags: Below is an abbreviated list of items that if you see one or more of these on a product's SDS, the substance in question is hazardous, must be included in your Hazard Communication Plan, and may need to be disposed of as hazardous waste.
- It can damage eyes, skin, mucous membranes, or lungs;
Personal protective equipment (PPE) is required with normal use of the product;
- It has a closed cup flash point less than 60 °C (140 °F);
- It is an ignitable compressed gas;
- It is an oxidizer or an explosive in its current form;
- It has a statement declaring it is forbidden to be offered for transportation according to 49 CFR 172.101 and 49 CFR 173.21;
- It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5;
- It reacts with water – violently, produces dangerous vapors, etc.;
- A statement declaring the product RCRA, OSHA, or DOT regulated as hazardous; or
- A disposal statement that the product or its container needs to be disposed of as hazardous waste under the RCRA.
Conducting an SDS library compilation or review
The following flowchart will help you manage your SDS library. When finished, your SDS library will contain SDSs of all the products that may be considered hazardous substances.
Print this chart
- The U.S. Occupational Safety and Health Administration offers a section-by-section guide explaining what needs to be included in an SDS. This may help you familiarize yourself with the standard SDS format and the information you can find in an SDS.
Is the product listed by OSHA? If you have any products at your facility that are on the Occupational Safety and Health Administration (OSHA) list of hazardous substances, make sure you have included them in the SDS Library and in your Hazard Communication Plan. See 29 CFR 1910, subpart H and 29 CFR 1910 Subpart H, appendix A for the OSHA-listed products. Guidance for Hazard Determination for Compliance with the OSHA Hazard Communication Standard may also be helpful.
Is the product listed in the RCRA? https://www.avma.org/PracticeManagement/Administration/Pages/Definitions-What-is-Waste.aspx#ListedWaste
Is the product characteristic waste as described in the RCRA? https://www.avma.org/PracticeManagement/Administration/Pages/Definitions-What-is-Waste.aspx#CharacteristicWaste
Is the product listed by NIOSH? NIOSH List of Antineoplastic and Other Hazardous Drugs in Healthcare Settings, 2016
Final stages of SDS Review
After you have identified all the SDSs with red flags and hazardous qualifiers as depicted in the flowchart and have added them to the SDS Library, the remaining SDSs need to be compared to the various lists and characteristics of items requiring hazardous waste disposal to help ensure your SDS Library is complete.
Marking the SDSs of items that fall into any of these hazardous groups will help in compiling your list of hazardous wastes generated by your clinic. In addition, hazardous waste classifications may be noted on the manufacturer's package insert or product label; thus, be sure to read all product information. All items in your SDS library will need to have their disposal means identified.
Is the item listed by OSHA?
- If so, add it to the SDS Library.
- According to the Occupational Safety and Health Administration, the following products must be included in your Hazard Communication Plan, regardless if they need to be disposed of as hazardous waste (see 29 CFR, section 1910, subpart H). OSHA regulates the Hazard Communications, whereas the EPA and the states regulate hazardous waste disposal.
- Compressed gases (acetylene, hydrogen, nitrous oxide, oxygen);
- flammable and combustible liquids and materials;
- explosives and blasting agents;
- anhydrous ammonia; and
- a list of hazardous chemicals.
Is the product listed in the Resource Conservation and Recovery Act (RCRA)?
- For the remaining SDSs as well as the ones already in your SDS Library, you will need to determine if any are listed in the RCRA.
- All that are listed will need to be disposed of as hazardous waste at the time of disposal.
The EPA's Substance Registry Services (SRS) may be a valuable tool to help you find the answers you need more quickly.
- Compare your SDSs and inventory/purchase records to the table of F-listed products in the RCRA (40 CFR 261.31). For veterinary practices, the F001 through F005 subcategories are most relevant. Any product in your records and/or SDSs that is also listed in this table is considered hazardous waste and should be handled and disposed of in compliance with OSHA and EPA regulations.
- For some of these products, pay careful attention to the SDSs for materials used in your laboratory.
- Acetone falls into this category
- Check to see if you have any products that are P-listed products in the RCRA (40 CFR 261.33).
- These are chemicals that are acutely toxic, which means that a very small amount (LD50 of 50 mg/kg or less as an oral dose) has severe or lethal effects.
- Warfarin, epinephrine (but not epinephrine salts), and nitroglycerine, are P-listed.
- Check to see if you have any products that are U-listed products in the RCRA (40 CFR 261.33). This list appears after the P-listed items in the same section of the RCRA.
- These are chemicals that are toxic and possess other characteristic waste properties (ignitability, corrosivity, or reactivity).
- Mercury and phenol are in this group.
- Although not expected to be in veterinary practice, checking to see if you have any products which are K-listed by the RCRA (40 CFR 261.32) is recommended.
- These are hazardous wastes from specific sources such as manufacturing pesticides, pigments, chemicals, wood preservatives, etc.
- They are generally not found in veterinary practices; but, these may be found at facilities that manufacture veterinary pharmaceuticals.
Is the product characteristic waste as described in the RCRA?
- For the remaining product SDSs as well as those already in your SDS Library for products not already categorized as qualifying as hazardous waste when time for disposal you will need to determine if any will require hazardous waste disposal because they possess characteristics described in the RCRA.
- All that are characteristic waste will need to be disposed of as hazardous waste at the time of disposal.
- If the SDS of any product lists any of the following characteristics of hazardous waste as described by the EPA, it should be treated as hazardous waste.
- Ignitability (EPA Hazardous Waste Number of D001)
- Corrosivity (EPA Hazardous Waste Number of D002)
- Reactivity (EPA Hazardous Waste Number of D003)
- Toxicity (differing EPA Hazardous Waste Numbers, as indicated in Table 1 of 40 CFR 261.24)
Is the product listed by NIOSH?
All that are listed by NIOSH will need to be disposed of as hazardous waste at the time of disposal.
- Some examples of products that may be used in veterinary medical practice that are listed in this document include, but are not limited to, Bacillus Calmette-Guerin (BCG), carboplatin, chloramphenicol, cisplatin, dactinomycin, doxorubicin, estradiol, finasteride, fluorouracil, some types of interferon, medroxyprogesterone acetate, methotrexate, mitotane, oxytocin, paroxetine, progestins, tacrolimus, vinblastine, vincristine, and more.
Any products that were found to be listed or characterized by the RCRA or NIOSH, or that are mixed with or contaminated by them are hazardous wastes when being disposed of.
- All of these products need to go on your list of hazardous wastes generated by your facility.
- You must ensure they are disposed of through means designed and approved for hazardous waste disposal.
- Documentation of the amount produced is also required.
- Dual waste (hazardous waste that is also regulated medical waste) needs to be disposed of separately.
- Mixed waste (hazardous waste that is also radiological waste) needs to be disposed of separately.
Too much work?
Try using one of the online hazardous waste decision trees
Updating your SDS library
Any time you receive an updated SDS for a product used in your practice, you should compare it to the corresponding one already in your SDS library for any indications that you need to alter your practice's safety precautions for handling, storage, use, or disposal. In addition, you need to determine if you must alter your Hazard Communication Plan and staff training procedures.
Want to save time in the future?
Create your own spreadsheet to help you keep track of important points relating to your hazardous substances.
- This way you can sort your SDS Library by different categories depending on your need such as
- Chemical name
- CAS #
- Product name
- Disposal means
- PPE level required
- In the spreadsheet you may also want to hyperlink the product to its corresponding online SDS