Converting USA-Format MSDS to EU (ANSI) Standard

by Dr. Jerome Elhaik and David Grunwald, Global Translations

Many chemical manufacturing companies in the US use an 8-header OSHA format for their Material Safety Data Sheets (MSDS). Some US companies maintain their MSDS in the ANSI format, which has a few distinct advantages over those prepared using the OSHA standard (the main advantage being that it is in the 16-header format and can be used in most countries with little modification). But in most cases, regardless of the format being used, the MSDS needs to be modified and adopted to the EU standard for use and approval in European countries.

This paper provides some guidelines for the process of converting an MSDS into European format. It is important to verify compliance with the EU standard before getting your MSDS translated into other languages. Making sure your English language MSDS’s are EU-compliant prior to translation will save you money and time, thus speeding up the time to market of your chemical products.

The guidelines are based on real projects that were done for Global Translation clients who needed to convert their MSDS for use in Italy, France, Germany, Switzerland and other European countries. These clients include Transmate, UCT Coatings, Gerber Scientific and the UCM Group.

US MSDS

Here are some examples of US MSDS (fewer headers than the 16-header format required by the EU).

Example 1 Example 2 OSHA Format
  1. General information
  2. Hazardous ingredients
    1. Sara title iii information
    2. CERCLA information
    3. RCRA information
  1. Physical/chemical data
  2. Fire and explosion data
  3. Reactivity data
  4. Health hazard (acute/chronic)
  5. Emergency and first aid
  6. Personal protective measures
  7. Special precautions
  1. Product identification
  2. Ingredients
  3. Physical data
  4. Fire and explosion hazard data
  5. Reactivity data
  6. Storage and handling information
  7. Health hazards and first aid
  8. Special protection information
  9. Spill or leak procedures
  10. Additional information
Chemical Identity

  1. Manufacturer’s Name and Contact Information
  2. Hazardous Ingredients/Identity Information
  3. Physical/Chemical Characteristics
  4. Fire and Explosion Hazard Data
  5. Reactivity Data
  6. Health Hazard Data
  7. Precautions for Safe Handling and Use
  8. Control Measures

ANSI Format

Here is the ANSI format which is very close in organization and content to the EU standard.

  • Identification of the substance/preparation and of the company/undertaking
  • Composition/information on ingredients
  • Hazards identification
  • First aid measures
  • Fire-fighting measures
  • Accidental release measures
  • Handling and storage
  • Exposure controls/personal protection
  • Physical and chemical properties
  • Stability and reactivity
  • Toxicological information
  • Ecological information
  • Disposal considerations
  • Transport information
  • Regulatory information
  • Other information

CONVERSION

The following are guidelines for each of the 16 sections in the EU-compliant MSDS.

SECTION 1: IDENTIFICATION OF THE SUBSTANCE/PREPARATION AND OF THE COMPANY/UNDERTAKING

* Identification of the substance or preparation: Name and reference number (Introduction in the OSHA format, Section 1 in other US MSDS)

* Use of the substance/preparation (Introduction in the OSHA format, Section 1 in other US MSDS, sometimes not present in US MSDS)

* Company/undertaking identification: copied from Section 1 or name of the company that distributes the product in the Member State

* Emergency telephone: USA CHEMTREC (Section 1) + other local member (ex: poison information centre (Giftnotruf, Germany))

SECTION 2: COMPOSITION/INFORMATION ON INGREDIENTS

Ingredient name CAS# % EINECS# Classification
Europe/Italy, France, Netherlands, Germany, United Kingdom (UK), Switzerland, Spain
xxxxxxxx xxxx % xxxx Symbols of danger and R phase numbers
xxxxxxxx xxxx % xxxx Symbols of danger and R phase numbers
xxxxxxxx xxxx % xxxx Symbols of danger and R phase numbers
See section 16 for the full text of the R phrases declared above

All the information above is in Section 2. The EINECS number is sometimes not present in the US MSDS: can be found at http://ecb.jrc.it/esis/

The R phrases and the symbols of danger can also be found at the same address when entering the adequate number.

If the R and S phrases are not listed, search using the CAS or EINECS number.

SECTION 3: HAZARDS IDENTIFICATION

The preparation is classified as dangerous according to Directive 1999/54/EC and its amendments.

Symbols : the two main ones

Classification:

Symbol letter; corresponding R phrase number

The two main ones

Human health hazards:

Text of the 2 phrases corresponding to the numbers above.

See Section 11 for more detailed information on health effects and symptoms.

For the classification of preparations (and for the preparation of the EU MSDS in general), see the paragraph 3.6 of www.impub.co.uk/dti/Part%202.pdf

SECTION 4: FIRST AID MEASURES

EMERGENCY OVERVIEW: from Section 1 or Section 6 (Section 6 in most cases)

N.B: This sub-section can also be found in the “Toxicological Information”, Section 11 in the EU MSDS.

INHALATION:

SKIN:

EYES:

INGESTION:

See Section 11 for more detailed information on health effects and symptoms.

The information above can be found in the “First Aid” section (section name and number vary, Section 6 in the OSHA format)

SECTION 5: FIRE-FIGHTING MEASURES

EXTINGUISHING MEDIA:

UNUSUAL FIRE AND EXPLOSION HAZARDS:

SPECIAL FIRE FIGHTING PROCEDURES:

The information above can be found in the “Fire and Explosion Hazard Data” section (the number varies, Section 6 in the OSHA format)

SECTION 6: ACCIDENTAL RELEASE MEASURES

Personal precautions: Immediately contact emergency personnel. Keep unnecessary personnel away. Use suitable protective equipment (Section 8). Follow all fire fighting procedures (Section 5).

(This is a general text which can be used for any hazardous substance if nothing else is specified)

Environmental precautions and cleanup methods:

Note: See section 8 for personal protective equipment and section 13 for waste disposal.

The information above can be found in the “Spill or leak procedures” section (name and number vary, sometimes included in Special, Section 7 in the OSHA format)

SECTION 7: HANDLING AND STORAGE

HANDLING:

STORAGE:

Packaging materials:

Recommended: Use original container

The information above can be found in the “Safe Handling and Use” section (name and number vary, sometimes included in Special, Section 7 in the OSHA format)

SECTION 8: EXPOSURE CONTROLS/PERSONAL PROTECTION

Occupational exposure limits:

The European OEL’s are different from the US ones, so if the European values are not provided by the supplier, this sub-section should be ignored (this is what happened for the first two sets of MSDS)

Exposure controls:

RESPIRATORY PROTECTION:

SKIN:

EYES:

VENTILATION:

OTHER PROTECTIVE EQUIPMENT:

The information above can be found in the “Precautions” section (name and number vary, Section 7 in the OSHA format)

SECTION 9: PHYSICAL AND CHEMICAL PROPERTIES

General information:

APPEARANCE & ODOR:

Important health, safety and environmental information:

pH:

BOILING POINT: in °C (needs to be converted from the value given in °F in the US MSDS)

FLASH POINT: can be found in the “Fire and Explosion Hazard Data” section (the number varies, Section 6 in the OSHA format)

EXPLOSIVE LIMITS: LEL and UEL: can be found in the “Fire and Explosion Hazard Data” section (the number varies, Section 6 in the OSHA format)

OXIDISING PROPERTIES:

VAPOR DENSITY:

SPECIFIC GRAVITY:

SOLUBILITY:

FAT SOLUBILITY (SOLVENT – OIL TO BE SPECIFIED):

PARTITION COEFFICIENT: N-OCTANOL/WATER:

VISCOSITY:

% VOLATILE:

EVAPORATION RATE:

WT/GALLON is exactly the same thing than Specific Gravity, so it can be removed in the EU MSDS.

The information above can be found in the “Physical/chemical data” section (Section 3, name varies).

These properties can be referred to as “N/A” for non applicable (for example, the pH for a liquid), or “ND” for not determined, if they have not been determined.

SECTION 10: STABILITY AND REACTIVITY

STABILITY:

INCOMPATIBILITY (MATERIALS TO AVOID):

HAZARDOUS DECOMPOSITION PRODUCTS:

HAZARDOUS POLYMERIZATION:

This section is completely to the “Reactivity data” section in the US MSDS (section number varies, Section 5 in the OSHA format)

SECTION 11: TOXICOLOGICAL INFORMATION

EMERGENCY OVERVIEW: from Section 1 or Section 6 (Section 6 in most cases)

N.B: This sub-section can also be found in the “First Aid measures”, Section 4 in the EU MSDS.

EFFECTS OF OVEREXPOSURE:

INHALATION:

EYES:

SKIN:

INGESTION:

CHRONIC EFFECTS AND MEDICAL CONDITIONS:

ACUTE DERMAL TOXICITY:

ACUTE ORAL TOXICITY:

ACUTE INHALATION TOXICITY:

CHRONIC TOXICITY:

Mutagenicity:

Reproductive effects:

The information above can be found in the “Health Hazard Data” section (section name and number vary, Section 6 in the OSHA format)

SECTION 12: ECOLOGICAL INFORMATION

Ecotoxicity:

Mobility:

Persistence and degradability:

Bioaccumulative potential:

Other adverse effects:

The information above is not often present in the US MSDS (sometimes briefly included in the “Safe Handling and Use” section, name and number vary, Section 7 in the OSHA format).

Or even if there is an ecological section (such as in the Trans-Mate products), they specifically refer to US standards, and are therefore irrelevant.

SECTION 13: DISPOSAL CONSIDERATIONS

Methods of disposal:

Waste classification:

European waste catalogue (EWC):

Hazardous waste:

The information above can be found in the “Safe Handling and Use” section (name and number vary, Section 7 in the OSHA format).

SECTION 14: TRANSPORT INFORMATION

Regulatory information UN number Proper shipping name Class Packing group Label Additional information
ADR/RID Class can be found in Section 1 can be found in Section 1 can be found in Section 1 can be found in Section 1 Can be found at http://en.wikipedia.org/ wiki/Dangerous_goods Kemler #:
AND Class Kemler #:
IMDG Class Kemler #:
IATA-DGR Class Kemler #:

SECTION 15: REGULATORY INFORMATION

EU regulations:

Symbols of danger (same than in Section 3)

ADR symbol (orange plate split in two parts: the Kemler code (the way it is determined is exposed at the page below on the upper part, and the UN number in the lower one).

It replaces the NFPA 704 diamond label in the US MSDS sheet.

See example below

http://fr.wikipedia.org/wiki/Transport_de_mati%C3%A8res_dangereuses

968
3082

Risk phrases: See section 2

Safety phrases: See section 2

Contains: Specify the contents with the CAS number in brackets (See section 2)

Product use: Classification and labeling have been performed according to EU directives 67/548/EEC, 1999/45/EC, including amendments and the intended use.

France

Netherlands

Germany

Hazard class for water:

See

http://www.umweltbundesamt.de/wgs-e/vwvws.htm

and

http://en.wikipedia.org/wiki/Material_safety_data_sheet#Water_hazard_classes

To find the class of an individual components, see

http://www.umweltbundesamt.de/wgs-e/mysql-wgk.html

To determine the class of a mixture see Annex 4 of

http://www.umweltbundesamt.de/wgs-e/archiv/vwvws170599.pdf

Switzerland

LRV Klasse (Ta-Luft):

See

http://en.wikipedia.org/wiki/TA_Luft

Italy:

Restriction on the use of Benzol and similar materials:

SECTION 16: OTHER INFORMATION

Full text of R phrases referred to in Section 2 and 3 – Europe, France, Netherlands, Germany, United Kingdom (UK), Switzerland, Spain:

List of R phrases

Full text of classifications referred to in Section 2 and 3 – Europe, France, Netherlands, Germany, United Kingdom (UK), Switzerland, Spain:

List of symbols of danger (all of them, not only the two main ones)

At the end of the document, paragraph on liability: can simply be copied/pasted from the US sheet.

References

http://www.unitar.org/cwg/publications/cbl/ghs/Country_org/EC.htm
http://www.ilpi.com/msds/ref/ansi.html