What is an MSDS and who is responsible for it?
A Material Safety Data Sheet (MSDS) is a document that provides information on the potential hazards (health, fire, reactivity, environmental) of a chemical product. It also contains instructions on how to use, store and handle chemical products safely, as well as potentially life-saving guidelines on what to do in the case of an emergency − spillage, overexposure, etc.
Many workplaces use dangerous chemical products – from industrial plants, to labs, to the cleaning supplies found in every office. Improper handling of chemical products can cause damage of staggering proportions through explosion, fire, and/or the release of lethal toxins into the atmosphere.
With so much at stake, national and global regulators have established a clear chain of responsibility for educating users on how to safely handle hazardous products and how to respond to an emergency: the manufacturers are required to prepare a detailed MSDS that covers all the mandated topics and to update them regularly, typically every three or five years; suppliers are required to deliver, along with the product, the most updated material safety data sheets in all the languages relevant to the buyer; and employers are required to make the MSDSs readily available to their employees.
Basic MSDS requirements
There are a number of harmonized and national regulations that dictate the basic content and format of the MSDS [i]. Thus, for example, the European Union’s REACH (Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals), requires that the following 16 topics be covered [ii]:
|1. Product, manufacturer, supplier info
2. Composition of ingredients
3. Identification of hazards
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Recommended handling & storage conditions
8. Exposure controls / Personal protection
|9. Physical and chemical properties
10. Stability and reactivity data
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory classification
16. Other information, disclaimer, etc.
Making MSDS Understandable
As noted in Canada’s Workplace Hazardous Materials Information System guidelines [iii], in the past the intended readers of MSDSs were occupational hygienists and safety professionals. Today, however, the audience also includes employers, workers, supervisors, nurses, doctors, and emergency responders. Thus, in order to ensure that MSDS users can quickly find the information that they need, the MSDS should be in an easy-to-read format and written in a clear, precise and understandable manner.
Not only must MSDSs be clearly written, they must be carefully localized[iv]. For one thing, they must be adapted to regional regulatory specificities such as the emergency call number in section 1, the occupational exposure limit values in section 8, and the list of the regulations that correspond to the substance in section 15.
MSDS Translation Challenges
In addition, they must be provided in the language of the user. REACH, for example, states explicitly (article 31, paragraph 5) “The safety data sheet shall be supplied in an official language of the Member State(s) where the substance or preparation is placed on the market, unless the Member State(s) concerned provide otherwise.”
Translating MSDSs is a mission-critical responsibility that should only be undertaken by knowledgeable and experienced translators. Not only must they be chemistry subject matter experts, they must be well-versed in the MSDS requirements of the target audience. In addition, they must be working within a well-established quality system that ensures accurate, consistent deliverables. The well-being of people, the environment and valuable assets are dependent on always-accurate, always-understandable MSDS translations.