Survival Tip 4 – Material Safety Data Sheets
By Steven De Lisi
As a first responder, you are dispatched to a report of a leaking 55-gallon drum at a nearby warehouse. Upon arrival, you determine that all personnel have safely evacuated the building and all are unharmed. They report a small leak from the container. You take the necessary precautions to secure the scene and in preparation for the arrival of the local hazardous materials team, you request a copy of the Materials Safety Data Sheet (MSDS) from the warehouse supervisor. To your surprise, he states there are no copies of MSDS available for any of the materials stored in the warehouse.
During a previous incident involving a tractor trailer with a leaking container at a truck stop, you requested the shipping papers from the driver, expecting to find MSDS attached. There were none. You had a similar experience when you responded to a report of a minor chemical spill at a retail store. When you asked the manager for a copy of the MSDS, he informed you that he was not required to provide one for materials his employees did not use. During each of these incidents, you distinctly recall the instructor during your Hazardous Materials Awareness training stating that MSDS would be available to first responders at any incident involving commercial occupancies and transportation emergencies. What went wrong?
MSDS can be used by first responders to learn a great deal of information regarding the many chemicals they may encounter during a hazardous materials emergency. Yet, there are some myths that affect what MSDS really are and how and when these documents can be obtained. It is important to remember that most MSDS used by first responders are based upon requirements found in OSHA standard 29 CFR 1910.1200, entitled Hazard Communication and that this standard deals directly with information that must be made available to employees who use chemicals, not first responders. While a federal law known as Emergency
Planning and Community Right-to-Know Act (EPRCA) found in Title III of the Superfund Amendments and Reauthorization Act (SARA) of 1986 requires those who
store and use certain hazardous materials in various quantities to forward MSDS to local fire departments (along with Local Emergency Planning Committees)
there are many more MSDS that first responders will NOT receive in this manner. And of course, for those MSDS that are sent to localities, the real
challenge for most first responders is getting these documents to the front seat of their apparatus during an emergency.
The OSHA standard lists several general categories of information that must be included on MSDS but does not require a standard format. Therefore, while
most any MSDS will contain information relative to each required category, first responders may find that the layouts appear different and somewhat confusing. Typically, MSDS will provide information related to the chemical and physical properties of a particular chemical. These include characteristics such the appearance (including color and viscosity), vapor density, and specific gravity, as well as the flash point and flammable limits for materials that will burn. Health hazard information often includes the primary route(s) of entry (skin absorption, inhalation, or ingestion), permissible exposure limits, and recommendations for medical treatment. First responders should always be concerned about any reference to delayed health effects. This characteristic of hazardous materials could include delays of 24 – 72 hours and may play a role for first responders as well as others exposed to hazardous materials who deny medical care because they do not appear to suffer any ill effects immediately after exposure. Most MSDS will also provide guidelines for dealing with spills, fires, and chemical reactions from contact with other materials. Probably the most important information available to first responders is the
name, address and telephone number of the chemical manufacturer or other individual who can provide immediate information regarding appropriate emergency
procedures. Remember that unlike the Emergency Response Guidebook, MSDS will rarely provide first responders with emergency evacuation and isolation
First responders should also be aware that chemical manufacturers are allowed to withhold specific chemical identities from MSDS, including the chemical name
and other specific identification of a hazardous chemical if the manufacturer claims that this information is considered to be a trade secret. However, relative to patient care, the OSHA Hazard Communication standard states that “Where a treating physician or nurse determines that a medical emergency exists and the specific chemical identify of a hazardous chemical is necessary for emergency or first-aid treatment, the chemical manufacturer shall immediately disclose the specific chemical identity of a trade secret chemical to that treating physician or nurse, regardless of the existence of a written statement of need or a confidentiality agreement.”1
The standard does allow the chemical manufacturer to request a confidentially agreement to protect their trade secret as soon as circumstances permit.
So just how do first responders obtain a copy of MSDS?
Remember that because the emphasis regarding hazard communication is on employees who use chemicals
in the workplace, first responders should not expect to have MSDS readily available upon arrival at every incident. These include those that involve transport vehicles and those that occur at retail stores and warehouses. In particular, remember that while federal transportation regulations state that some form of emergency response information must be available with shipping papers, the use of MSDS to meet this requirement is optional rather than mandatory. Therefore, while some truck drivers, such as those hauling a single commodity in a cargo tank may have a copy of a MSDS available, most shippers and carriers can meet the requirement for emergency response information using the Emergency Response Guidebook. For retail stores and warehouse, employers are usually not required to provide their employees with a MSDS if they only handle chemicals (such as using a forklift or hand truck) in sealed containers which are not opened.
As stated earlier, for locations where chemicals are used, employers are usually required to provide their employees with copies of MSDS. However, first
responders must always remember that the OSHA standard 1910.1200 does not require that MSDS be readily available, but only that MSDS be readily accessible.
This can mean that instead of maintaining a book containing numerous MSDS, an employer can provide electronic access to these documents using computers or fax machines. If this is the case, first responders who evacuate a building housing the computers and fax machines will now need to obtain MSDS in some other
manner. For situations when first responders cannot enter a facility to obtain MSDS and for those that involve transportation incidents, warehouses, and retail outlets, they will likely need to contact the chemical manufacturer for the MSDS.Remember that CHEMTREC may be able to help you reach these individuals and on some occasions they may have a copy of the MSDS. Never hesitate to contact CHEMTREC at (800) 424-9300 for assistance in locating MSDS.
Once first responders locate the required MSDS, they can have these documents faxed to a nearby location, such as a neighboring business or the local emergency dispatch center. If possible, they should make several copies of this document realizing that hazardous materials teams, medical personnel on-site, hospitals, and cleanup contractors should all have a copy during any incident. When using paper copies of MSDS obtained directly from a facility, first responders should be aware that these MSDS could be out of date. It is recommended that first responders always check with the manufacturer (whose telephone number should be on the MSDS) to make sure that the MSDS they are using is current.
When using MSDS, be smart, be safe, and remember, everyone goes home!
1.For those MSDS required by federal law to be submitted to your locality, determine who receives these documents and how first responders can access this information. Learn where these materials are located in your community.
2.Obtain copies of these MSDS and practice locating the following information:
Chemical name and synonyms (different names for the same chemical)
Lower and upper explosive limits
Procedures for dealing with fires
Procedures for dealing with spills (including recommended absorbents)
Potential for environmental impacts
Potential for explosion or reaction with other materials
Signs and symptoms of exposure
Primary routes of entry
Emergency first aid procedures
Date the MSDS was prepared or changed
Name and telephone number for the manufacturer
3. Contact the manufacturer at the number provided on each MSDS to determine if the MSDS is current and to ensure that this number still works. Don’t be surprised if changes have occurred!
1 29 CFR 1910.1200 (i) (2)
For information on Steven DeLisi’s book Hazardous Materials Incidents: Surviving the Initial Response
go to: store.pennwellbooks.com/hamainsuinre.html
Steven M. De Lisi is Deputy Chief for the Virginia Air National Guard Fire Rescue located in Henrico County and a 26-year veteran of the fire service. He has served as a company officer for the Newport News (VA) Fire Department and as a regional training manager for the Virginia Department of Fire Programs. He is a certified Hazardous Materials Specialist and previously served with the Virginia Department of Emergency Management in the Technological Hazards Division. De Lisi is currently chairman of the Virginia Fire Chiefs Association’s Hazardous Materials Committee and a former member of the National Fire Protection Association’s committee on Hazardous Materials Protective Clothing.