Do I Need an SDS for Hazardous Products Not Classified by GHS?

Many workplaces may have hazardous products like pesticides, paints, welding rods, or batteries that may not be classified under GHS.

Many suppliers of products that are not classified under GHS have a safety data sheet (SDS) for the product (for example, consumer cleaning products). Products can claim to be non-hazardous or safe for household use, however, bringing them into the worksite often means they are used in greater quantities and used more regularly. If this is the case, the regulation (WHMIS or HazCom) makes the employer responsible for a Safety Data Sheet or Hazard Communication on the hazardous product.

Key Takeaways

• No GHS classification does not mean no hazard. Pesticides, welding rods, compressed gases and many store-bought products can still harm workers.
• Workplace use changes the rules. A consumer product used more often, in larger amounts or for longer than a household would use it is treated as a workplace hazardous product, and the employer needs its SDS.
• Some exemptions only move the paperwork. Pesticides are labelled under the Pest Control Products Act in Canada and by the EPA under FIFRA in the United States, but employers must still inform and train workers about their hazards.
• Keep the SDS even when a product is “non-hazardous”. An SDS on file is proof of safety, supports worker training, and covers handling, storage and transport details the label leaves out.

Do I need an SDS for products purchased at the hardware or grocery store?

You need an SDS for every hazardous product you use in the workplace. It is important to understand the purpose and use of any product brought to the workplace when determining if an SDS is required.

By law, hazardous product suppliers must give you an SDS when you purchase the product. There is an allowance for cases of small quantity, “consumer” customers; that is why hazardous products from hardware and grocery stores are not sold with an SDS.

Hazardous products exempt from GHS classification

Other hazardous products that are exempt from GHS classification include herbicides, fungicides, and insecticides. These products are covered under the Pest Control Products Act (PCPA) in Canada and regulated by the Environmental Protection Agency (EPA) under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) in the United States. As noted above, not carrying a classification under GHS does not mean they are not hazardous - some pesticides present severe health hazards such as organ and reproductive toxicity.

Products misrepresented as hazardous

Some chemical suppliers misrepresent their products as non-hazardous (welding rods/electrodes, flux) or have research to show that their product does not cause cancer (highly refined oils). In these cases, you want to have the SDS in your inventory even though it doesn’t carry a GHS classification. There are always new and improved cancer studies, and the list of carcinogens is not shrinking.

Nontoxic products

Some chemicals such as laboratory solutions, buffers, indicators, latex paint, are nontoxic but the hazard information is valuable to have on file as proof of safety. Competent workers, trained in WHMIS will ask about the hazards of the chemicals they are using.

Products with only a physical hazard

Some products are a physical hazard rather than a health hazard (asphyxiant gases, compressed gases, combustible dust) making them an N by Chemscape’s current ranking system.

Products with special handling or transport instructions

Some products are non-hazardous but require special transportation or handling procedures (lithium batteries).

Which products need an SDS? A quick reference

Frequently Asked Questions

Do I need an SDS for a product that is not classified under GHS?

Often, yes. A product without a GHS classification can still be hazardous, and once it is used in the workplace the employer is responsible for communicating its hazards. Keeping the SDS on file is the simplest way to do that.

Do consumer products bought at a store need an SDS at work?

They do when the workplace uses them more often, in larger quantities or for longer periods than a household would. Stores are not required to hand out an SDS to small-quantity consumer buyers, so request one from the manufacturer or supplier.

Are pesticides exempt from WHMIS and HazCom?

Pesticides are labelled under the Pest Control Products Act in Canada and by the EPA under FIFRA in the United States, rather than under WHMIS or HazCom supplier rules. Employers must still make sure workers understand their hazards and how to handle them safely.

Why keep an SDS for a product the supplier calls non-hazardous?

Some products are labelled non-hazardous even though their use creates a hazard, such as fumes from welding rods. Cancer research also changes over time. An SDS on file gives workers and health and safety staff the information they need if the picture changes.

What does an SDS add for products that are only a physical hazard?

Compressed gases, asphyxiant gases and combustible dust may not harm health directly, but they can cause fires, explosions or oxygen-deficient air. The SDS sets out safe storage, handling and emergency response.

SDS management made easy with sdsBinders

SDSs are created to serve many purposes. Employers are required to provide workers and staff with training and education relating to safe handling, health effects and storage of even GHS-exempt products. With Chemscape’s SDS management software, sdsBinders, you can say goodbye to the paper chaos and complexity of chemical management. Contact Chemscape today to learn more.

Sources

• Hazardous Products Act | Justice Laws Website
• Pest Control Products Act | Justice Laws Website
• 29 CFR 1910.1200, Hazard Communication | OSHA