ARTICLE BY REBECCA M. BURTON, CIH, MPH
I first met Rebecca in 2008. She was the charge painter for an event for which I was the house electrician. When she moved to town a couple of years later, it was a terrific addition to the Twin Cities community. Rebecca is now an Industrial Hygienist for 3M, but she’s remained close to the Performing Arts community, and her powerful and informed interest in safety on the job ought to be an inspiration for us all. A brilliant person with that rare intellect that cuts right to the heart of any matter while still remaining very cognizant of pragmatic concerns, Rebecca is the kind of person we should all have been paying more attention to long ago. —Wu Chen
Let’s talk about safety data sheets. You know, those papers that come squashed between the cans in your paint order, or stuffed underneath the bottom of the packing supplies in your latest prop material orders. Or maybe your materials didn’t come with one at all, and when you asked the person in the store for it, they looked at you like you just asked them to fetch your unicorn from the valet parking.
Safety Data Sheets, or SDSs, are documents that the US Occupational Safety and Health Administration (OSHA) has mandated be provided with any material* produced and sold in the US that contains a chemical listed as hazardous. (For information on what counts as “hazardous,” you can have a blast digging through this standard). Since the most recent iteration of the Hazard Communication Standard (HazCom 2012) took full effect, SDSs must follow a mandatory 16-section format and contain certain required information presented in a certain required order. They tend to be a big improvement on SDSs published before HazCom 2012.
*With a few exceptions, like pesticides, cosmetics, food, and drugs, which are regulated under different agencies.
But they can still be really confusing. Some list ingredients in one section but not another, or list health effects that don’t seem to line up with any of the listed ingredients, some block you altogether under the useful banner “trade secret,” and some just don’t say anything at all, and are full of line after line after line of “no data,” “no data,” “no data.” As someone who, on average, reviews upwards of 30 SDSs a week, I thought it might be helpful to take an arts-minded look through some and give you a bit more detail on how you can really dig the information you need out of them.
This tutorial is geared towards a typical theater craftsperson; who uses a lot of different materials to do their work, from paints and coatings, to solvents, cleaners, lubricants, dyes, etc., and may not always be using the material in question the way it was intended.
Right off the bat, if you can get your hands on a version of the SDS produced for customers in Europe, it’s likely to have a lot better information on it. Under REACH, the European Union put in much tighter requirements around what had to be documented, and while US manufacturers more or less reacted like a child told to clean up its room or get no dessert, they have ultimately had to comply if they want to continue exporting to Europe. Sometimes you can find the European versions on the manufacturer’s website, or on a vendor’s website. It’s not a huge deal; I wouldn’t go off the deep end about it, but it’s worth a few-minute web search.
Now, on to the SDS itself.
Section 1: This will tell you what the material is, whether it's a mixture or an individual chemical. Sometimes it will tell you what the material is intended to be used as, such as a filler, pigment, coating, or other kind of ingredient. This can help you think about how the manufacturer is intending the material to be used, which you may or may not be planning to do. This section must also provide information about the manufacturer, where they are located, and how to contact them, both by mail and telephone. This section is also supposed to contain the date on which the SDS was updated.
Section 2: Hazard Information. This is the meat of the SDS. It must contain pictograms telling you what type of hazards the material presents, hazard statements stating what the dangers of the materials are, and precautionary statements advising readers on how to avoid those dangers. There have been reams and reams of materials published on HazCom pictograms et al., so I won’t get into it in detail. From a high level, the exploding chest pictogram means something in the material causes some kind of disease or organ damage, the skull and crossbones mean at least one ingredient is acutely toxic or fatal by at least one exposure route, and the dissolving-substance-and-hand pictogram means at least one ingredient is corrosive (or at least highly irritating) to skin and/or eyes.
Section 3: One of the more frustrating sections, Section 3 is supposed to tell you any hazardous ingredients in the material, their CAS numbers, and what percentage of the mixture (if it is a mixture) they comprise. When you’ve got names and CAS numbers, you can look up information on those chemicals in other places to see more detail. My first stop is always the GESTIS database (I will never stop singing its praises), which gives all the information you could ever hope to see in terms of physical and chemical properties, toxicology studies, PPE recommendations, and guidance for handling the chemical safely.
Too often, you will see one or more of these required pieces of information (name, CAS, percentage) withheld as a trade secret. If the percentage is withheld, sometimes they’ll give a range: for example, “35-80% by weight.” This is…less unhelpful. When it’s the name and/or CAS number that’s withheld, it’s quite unhelpful, and there are a couple of other places you can look to get clues.
First off, look at section 8, which may contain exposure limits. Then look at section 11, which is supposed to have toxicology and health effects details. Then look at sections 14, 15, and 16, which are supposed to contain, respectively, transporting information, regulatory information, and “other.” We’ll get to why these might contain secret ingredients later, when we get to those sections. Also, look at the ingredients list on the material’s container. Because labeling of ingredients is regulated by different laws than HazCom, you’ll often get a much clearer picture of what’s in the stuff from the label. (I know. I know. This is why people like me have entire full-time jobs dealing with this kind of shenanigans.)
Section 4: This section is supposed to contain first aid measures, which you’d think would be helpful, but I haven’t really found it so. They almost all say some version of the following: Eyes – rinse thoroughly with water and seek medical attention. Skin: Flush with water and seek medical attention. Inhalation: remove to location with fresh air and if symptoms persist seek medical attention. Ingestion: Do not induce vomiting. Seek medical attention. I suppose there are probably substances somewhere that require some really particular kind of immediate first aid, but I haven’t discovered them yet.
Section 5: Firefighting measures – Here again, this section is not super useful, because they tend to all recommend the same things: supplied air respirator and chemical protective clothing. However, sometimes here you will find a list of chemicals that may be released when the material burns, which is of material concern (here’s looking at you, foam-carvers).
Section 6: Accidental release measures. This section might give you some useful information on how to contain or clean up the material if you accidentally spill it, but these are mainly intended for industrial-scale spills.
Section 7: Handling procedures. This section may or may not be useful. It should give you a heads up if there are any other chemicals it’s a bad idea to store or use close to this one. It will almost certainly tell you not to let yourself be exposed to the material and use appropriate PPE (personal protective equipment), and use the material only in a well-ventilated environment. It will say not to eat or drink while using the material. It’s mostly obvious, vague, common-sense precautions, but you might occasionally get a nugget of useful information.
Section 8: Exposure Control – If the substance or one of its ingredients has an exposure limit, you’ll usually find that here. It may also have useful information like a particular glove material or respirator cartridge to use with the substance. It will also probably have warnings like “wash hands after use,” and should recommend chemical protective goggles for use with things that are damaging to eyes.
Congratulations! You’re now halfway through your SDS and should have some idea of what you’re dealing with in your material, even if that idea is, “whoa, these jerks won’t tell me ANYTHING about this stuff!” I’m going to wrap up Part I of the article here, partly since Tech Tools asked me to stay within 1500 words, and partly because I have a lot of things to say about physical and chemical properties that bear reading with fresh eyes. In the meantime, it’s never a bad idea to take a look through your shop’s SDS collection with a critical eye. If all you have are really old ones, you should take some downtime to get updated versions—part of the HazCom requirements are that businesses are required to have SDSs current within the last 5 years for any materials their employees are using—and the manufacturer has to provide them if requested. Thanks for reading, and have a safe and productive spring season!