How many times have you been asked by a customer for an MSDS? It is a widely misunderstood document and when a consumer requests one, it’s actually almost never what they really want. So let’s take a quick look at the (M)SDS, what it is and what it isn’t.
First, an MSDS no longer exists. It’s been replaced by the term SDS, or a Safety Data Sheet.
Second, the SDS has been significantly improved over the old MSDS. The original MSDS could take almost any structure present the information as the manufacturer felt best. The new SDS is a standardized document that has 16 specific sections so you always know where to go for the information you need. Language has likewise been more formalized and the graphics specified.
Third, that formalized language rarely includes the information that the consumer really wants, which would be VOC emissions levels and certifications, finish warranties, installation instructions or other technical information. Many consumers assume that an SDS is a consumer-oriented document and it is not—it is designed for a professional user on a job site or in a factory or for a first responder.
Now the big question is if you need an SDS for wood flooring? And the short answer would be “yes, it would be a really good idea,” according to local legal eagle Margaret Cerrato-Blue of Fox Rothschild. Margaret’s recommendation is based on OSHA requirements for workplace safety and additionally how California’s Proposition 65 relates to consumer vs. professional warning requirements. Her conclusions (highly simplified here!) would recommend notifying wood professionals of the hazards of wood dust.
She provides the details of her analysis as part of a longer memo she’s created for flooring companies that looks closely at issues of SDS and Proposition 65 label requirements. In that document, she concludes that “an OSHA Safety Data Sheet (SDS) should be made available to commercial and professional customers for potential occupational exposures to wood dust during installation of your solid wood, engineered wood, and laminate floors.”
Contact her for more information on the full package (which runs 40 plus pages!). The memo includes generic SDS templates that you can edit for your own products.
And if you prefer to do your own research, here are some useful links.
- OSHA’s Hazard Communication Standard (HCS) and Appendices can be found in the following link; Table D.1 in Appendix D shows the required format and minimum information required on SDSs: https://www.osha.gov/dsg/hazcom/ghs-final-rule.html.
- OSHA’s HCS website also includes helpful SDS guidance and additional resources for businesses:
- https://www.osha.gov/dsg/hazcom/;
- https://www.osha.gov/dsg/hazcom/guidance.html (guidance documents);
- https://www.osha.gov/Publications/OSHA3514.pdf (SDSs);
- https://www.osha.gov/Publications/OSHA3636.pdf (labels and pictograms)
- And finally, in Canada, the program known as the Workplace Hazardous Materials Information System (WHMIS) establishes the requirements for SDS’s in workplaces.
Elizabeth Baldwin is Environmental Compliance Officer for Metropolitan Hardwood Floors. In her 25 plus year career in the wood industry has visited over 70 countries and hundreds of facilities of all sizes and types. She describes herself as a “jack of all wood trades.” Familiar with jungles of all sorts–having camped out along the Amazon and walked the halls of Congress–she blogs for the NWFA on both environmental and regulatory issues for educational and informational purposes only. Her blog is not intended and should not be construed as legal advice. Persons seeking legal advice on compliance with CARB, TSCA, the U.S. Lacey Act or any other law, regulation, or compliance requirement/claim should consult with the regulatory agency directly and/or a qualified legal professional.