How OSHA, ANSI and GHS Impact MSDS for Sealing Products

The roots of material safety data sheets (MSDS) can be traced to prehistoric times, when information about materials used in medicines and dyes was exchanged verbally. The first written MSDS were found on papyrus rolls in the tombs of the ancient Egyptians.

By the mid-20th century, however, these documents had evolved into a means for manufacturers and trade groups to voluntarily provide information on how to safely use their materials.

Today, MSDS contain information prescribed by law, and are administered in the United States by OSHA as part of 29 CFR 1910.1200, the hazard communications standard. The primary purpose of this standard is to identify and communicate the potential hazards of workplace chemicals. Under this standard, most solid gaskets and other sealing products fall under the classification of “articles” as defined in paragraph (c):

“Article” means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical (as determined under paragraph (d) of this section), and does not pose a physical hazard or health risk to employees.”

Since the standard was issued in 1983, MSDS have become instruments of commerce. Even though articles and non-hazardous substances are exempt from the standard, MSDS for them have become a prerequisite for conducting business in many sectors, including the sealing industry. Most gasket and seal manufacturers provide MSDS for many of their products, either on their Web sites or on request. Interestingly, MSDS often are requested even for gaskets and seals that conform to regulations pertaining to contact with food (FDA), water (NSF) or pharmaceuticals (USP).

Unlike regulations in some countries, 29 CFR 1910.1200 does not specify a chronology for updating MSDS, nor does it specify a format. Many companies follow ANSI Z400.1 — 2004, American National Standard for Hazardous Industrial Chemicals — Material Safety Data Sheets — Preparation.

ANSI Z400.1 — 2004 AND MSDS

This is 16-part format aligns with the Global Harmonized System (GHS) set to replace the various classification and labeling standards of different countries.

Section 1, Product and Company Identification, links MSDS to the material label, identifies the manufacturer of the material and identifies a source for more information.

Section 2, Hazard Identification, provides an emergency overview, including physical properties, as well as significant physical hazards. It lists potential adverse human health effects and symptoms that might result from reasonably foreseeable use and misuse of the material and potential environmental hazards. It also lists OSHA regulatory status.

While an “article” may not be considered hazardous under normal conditions of use, the product still may pose a hazard under certain conditions. The most significant acute hazard that can occur with many gaskets and sealing materials is the generation of toxic vapors as a result of thermal decomposition. This is common to products containing such widely used polymers as polytetrafluoroethylene (PTFE), acrylonitrile-butadiene (NBR) rubber, fluoroelastomers (FKM) and silicone. Rarely are physical properties posing hazards such as fire, explosion and chemical reactivity found at significant levels in gasket and seal compositions. However, they may contain fillers and fibers that — if they become airborne at respirable dimensions — can pose potentially adverse effects on human health.