We’ve reached the end. Part Four of this blog post series on the structure of a Material Safety Data Sheet (MSDS) is ready to commence.
We’ve highlighted Dow Corning’s DC4 Electrical Insulating Compound in an attempt to dissect the sections (the basic structure) this type of document contains. This particular post will review the final block, Sections XIII-XVI. Are you ready for the grand finale? Let’s do this.
Section XIII: Disposal Considerations
Unlucky number 13? Possibly, but superstitions aside, in many ways Section XIII of a MSDS is the most critical. A product may or may not be used. Regardless, once its shelf life has expired or once its effectiveness has been compromised, it must be disposed of.
The first thing immediately mentioned is “RCRA Hazard Class (40 CFR 261)”. What is that? The Resource Conservation and Recovery Act (RCRA) is a U.S. law passed by Congress in 1976 to spell out a method for properly disposing of waste, especially those considered hazardous. The government agency responsible for setting RCRA guidelines and then enforcing them is the Environmental Protection Agency (EPA). According to the EPA’s website, regulations concerning hazardous waste are found under 40 CFR Part 260, which includes “waste identification, classification, generation, management and disposal.” CFR stands for Code of Federal Regulations and the 40 refers to the 40th Title of such a codification; Title 40 covers “Protection of Environment”. This title is further divided into parts (chapters) and subparts, one of them being 261, or “Identification And Listing Of Hazardous Waste.”
Right underneath is perhaps one of the most important questions and answers posed in the entire document: is this product classified as hazardous material? Luckily, DC4 does not fall under this designation. And this brings up a great point. Contrary to what some may misperceive, not all products with a MSDS are hazmat.
But let’s say an item was hazmat, what then? This section would not only verify this fact but it would also provide you with information as to any particular procedures that an item calls for when disposing of it. The DC4 MSDS, like many, states that you should abide by regulations established by federal, state, local, or any other applicable governing area where you use the product. A phone number is listed in order to gather additional information.
Section XIV: Transport Information
From manufacturer to retailer to end-user, all products obviously need to travel from place to place. Whether from land, water, or air, travel accommodations of sorts need to be met. That is where and when the Department of Transportation (DOT) and others get involved.
Similar to the previous section, a specific subpart of a CFR is mentioned, 49 CFR 172.101. You guessed it: Title 49 deals with “Transportation.” For those who just love legalese in all its glory you can read 49 CFR 172.101. DC4 is not subject to DOT. Thus, this product does not have any special requirements “for shipping papers, package marking, labeling, and transport vehicle placarding applicable to the shipment and transportation of those hazard materials.”
If a shipment of DC4 is on an ocean liner, there are no worries since the product is not subject to IMDG code. This code operates through the United Nations’ funded agency, the International Maritime Organization (IMO). The International Maritime Dangerous Goods (IMDG) code is used similar to the DOT’s CFR but on an international scale that covers services and industries relating to shipping.
Just as DC4 is not subject to other regulations, this product is not subject to IATA, or the International Air Transport Association. Periodically, the IATA publishes a set of Dangerous Goods Regulations (DGR). The most current version (as of this writing), is the 54th edition. You can view the most important changes to DGR 54 or simply check the IATA website from time to time.
Once again, Section XIV includes a contact number to make further inquiries and get more information.
Section XV: Regulatory Information
More regulations and more acronyms. Take a deep breath, this section’s a long one.
Back in Section III we mentioned OSHA’s (Occupational Safety and Health) involvement in a MSDS. For Section XV they make one final appearance, this time with a “Hazard Communication Standard 29 CFR 1910.1200.” CFR Title 29 deals with “Labor.” As for 1910.1200, this is the standard number of Title 29’s regulation. The purpose of it is to “ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees.” The specifics of the standard is a mound of text that could put Mt. Kilimanjaro to shame. If you want to take that trek, you can read 1910.1200.
TSCA refers to the Toxic Substances Control Act, a piece of legislation passed by the U.S. in 1976. While it regulates the use of new and pre-existing chemicals, it specifically targets use of products with polychlorinated biphenyl (PCB). In addition, its subchapters address dangerous substances that, prior to the 1970s, were left unchecked while being applied residentially or industrially. This includes asbestos, radon, and lead in particular. DC4 is free from such substances and that fact is affirmed in “TSCA Status.”
The EPA has also compiled a list of chemicals under the Superfund Amendments and Reauthorization Act (SARA Title III) of 1986. This is also known as the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986. What follows under “EPA SARA Title III Chemical Listings” is a breakdown of the EPCRA’s four sections, i.e. 302, 304, 311/312, 313, 314; the chemical ingredients within each section; as well as the different parts of CFR Title 40 they correspond to:
DC4 has no ingredients mentioned in this area of Section XV. However, it is important to see just how complex and how closely monitored products are when they contain anything threatening to users.
The other subsection, “Supplemental State Compliance Information” lists certain states that have passed their own legislation that may pertain to the product in question. California, New Jersey, and Pennsylvania are mentioned. The contents of DC4 are not considered toxic or otherwise harmful under California State Law. Worth noting is New Jersey and Pennsylvania: both states require manufacturers to list the chemical ingredients, including their name, CAS number, and percentage by weight. This is basically what Section III (or any section that deals with composition) of a MSDS would contain. Why this information is not found in DC4’s Section III is puzzling. It could be an error that may be corrected in a revised edition.
Section XVI: Other Information
There’s not much to say, here. Any other pertinent information, perhaps any special considerations that must be made according to a product’s specific design, would be mentioned in Section XVI. But honestly, in most cases all relevant details are listed in preceding sections.
To summarize, a product’s MSDS includes a lot of ingredients, a lot of acronyms, a lot of protocol, procedures, regulations….basically a lot of information. It’s ultimately the responsibility of the reader, the end-user of the product, to be aware of any issues concerning safety.
The MSDS for DC4 is indicative of Dow Corning’s approach to disseminating the appropriate information necessary to safely interact with their extensive product line. It follows a sleek and pleasant design that clearly delineates the different sections. This is in contrast to many MSDS from other manufacturers that have an almost haphazard layout. These kinds of MSDS are often confusing (in addition to the content), lack any depth, are incomplete, and are otherwise presented in a way that further dissuades any one from reading it let alone understanding it.
In an effort to make it easier to read, many companies are issuing a “Plain Language Hazard Summary” at the beginning of their MSDS. One great example is found when buying LPS® Hardcoat Corrosion Inhibitor. In the accompanying image, you see this new section admits to the confusing and technical nature of the MSDS and how it will just frustrate a “non-professional.” It’s good to see manufacturer’s writing with the audience in mind. Hopefully, this will become a standard carried out by all businesses in the near future.
So there you have it. I hope this was informative, educational, and a help to all who read. It may seem like a waste of time to read a MSDS, but at least it is peace of mind knowing the lengths that governments and related organizations are willing to go through to ensure the welfare of users. While it certainly would be nice to have a streamlined version, when you think about it a MSDS must be thorough, even at the risk of boring readers to death.
As always, until we meet again, stay safe out there…
***UPDATE*** Read other parts in the “ANATOMY OF A MSDS” blog post series