Safety Data Sheets (SDSs), formerly known as Material Safety Data Sheets (MSDSs), are a critical component, required by law, of safe manufacturing operations as they contain basic information about a chemical or product which helps to ensure the safety and health of the user at all stages of its manufacture, storage, use, and disposal. But are they really needed in food production?
As explained in the Guidance for Hazard Determination For Compliance with OSHA Hazard Communication Standard (29CFR1910.1200), manufacturers and importers are responsible for performing a hazard determination on the chemicals they produce to determine if, under normal conditions of use, their product could result in a hazardous exposure situation for downstream employees who will be working with or otherwise handling that product. “Chemical” is broadly defined in the Harmonized Communication Standard as “any element, chemical compound, or mixture of elements or compounds.” Chemicals, therefore, include food and food additives.
SDSs in the Food Facility
Food products, like any other chemical product, must be evaluated for their downstream hazardous exposure potential. As an example, employees who work with flour may be exposed to the potential hazards of explosion or combustion that may occur if flour becomes airborne in sufficient concentrations. Chemicals added to the food, such as sodium nitrate and sodium nitrite in processed foods, that could be hazardous must also be identified on an SDS.
Both of these cases represent potential physical hazards that would have to be noted on an accompanying SDS for that food product. In these cases, in addition to preparing an SDS, employers must also train employees about operating safely with those chemical hazards in the workplace. SDSs for all chemicals must located at or near the point where the chemical in question will be introduced so that the information is readily accessible. They must be updated at a minimum every five years. SDSs are an important component of food safety plans. Facilities without them, or without all that are required, will be found in violation during an FDA inspection or third-party certification audit.
Interestingly, SDSs have a long and involved history, extending back into time as far back as 4,000 years ago when MSDS-like records described pharmaceutical use in Egypt. A thousand year later, the Greeks recorded not only their own observations, but also some of their early experimental work on similar documents. Skipping ahead another millennium, chemical data sheets were continuously being developed by chemists at avante garde chemical companies as a way of transmitting various data to fellow chemists, including melting/freezing/flash points, viscosity, density, with additional items such as reactions and fire hazards. While health, safety and toxicological data had been in development over thousands of years, it is only recently that this information has been included on data sheets for an all-inclusive document.
The U.S. federal government got involved in the mid-1960s, developing its original Form LSB-00S-4 to meet the needs of maritime workers and adding safety and hazard information for the first time to a chemical safety sheet. With the passage of Public Law 91-596, on Dec. 29, 1970, OSHA was established within the Department of Labor and Form LSB-OOS-4 became Form OSHA-20, issued as “revised May 1972.”
On Nov. 25, 1983, OSHA issued its final regulation requiring MSDSs for all shipments of hazardous chemicals leaving a manufacturer’s workplace and from all importers of such on all shipments, to be implemented by November 1985. Distributors and employers were to comply as of that same date. All employers were to follow all provisions of this section, including initial training requirements for all current employees, by May 25, 1986. At that time, the formatting for MSDSs was fluid and varied considerably from company to company and from country to country. The European Union standardized the format into what is now the 16-section document, and the U.S. government created the Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requiring that the chemical manufacturer, distributor, or importer provide an SDS for each hazardous chemical to downstream users, with a standardized and more effective format to communicate chemical hazards than the MSDS. Additionally, the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) was set up with core elements that included standardized hazard testing criteria, universal warning pictograms, and harmonized safety data sheets that provide users of dangerous goods with a host of information on toxicity and safety protocols. The system also acts as a complement to the United Nations’ system of regulated hazardous material transport.