Material safety data sheets are one of those things that sound like a good idea – indeed an obvious one. If you are supplying a raw material you are required to provide the information the person who is going to use it needs to handle it safely. Makes sense.
This has become a really widespread practice and is now a legal requirement in most countries in the world. Chemicals are traded internationally and this makes it necessary to agree a standard format for safety sheets.
So far, so good.
The only trouble is that the whole business has become tremendously complicated, with lots of codes, acronyms and symbols involved. This doesn’t mean that they aren’t still a net benefit to health and safety. They clearly are. The world is a safer place because of them, and this justifies the effort that goes into them. But my feeling is that the complexity of the average material safety data sheet has now reached the stage where it is probably preventing it from being as useful as it ought to be. And I think everyone’s feeling is that the work involved in compiling them is time most people would rather spend doing other things.
As it happens, cosmetics are one of the categories specifically excluded from international agreements for the need for material safety data sheets. This of course makes perfect sense. The whole point of a material safety data sheet is so a technical manager can make informed decisions on how they are going to handle the stuff that has just been ordered. Or, in an emergency, how they are going to cope with the stuff that has just started leaking out of a ship. It really shouldn’t be necessary with a consumer product. You don’t need to carry out a risk assessment when you buy a shampoo in a shop. All that work should have been done by the supplier before it even reaches the shelves.
So there’s really no reason that the consumer even needs to know that MSDS sheets exist.
This point however is only of limited value to the busy cosmetics professional hoping to get an item off his or her to do list. Because while finished products are excluded, bulk cosmetics are not. So while you won’t have to draft one if you are making and filling the stuff at the same time, if you do just about anything else you are going to fall under the legislation. So if you manufacture on one site and put it on a lorry to be filled elsewhere, you need an MSDS. In fact this is hard to argue with. If the lorry turns over in transit somebody somewhere will have to deal with it and they need to know what they should and shouldn’t do. An eau de toilette spray is safe enough to handle around the house. A tonne of flammable material pouring out onto a road most certainly is not.
More arguable is if you make your bulk and rather than filling it directly, you put it into storage. You now need to work out your policy on how to handle it even though it is in-house, so once again it could be argued an MSDS will be needed.
Both of those cases are ones you really can’t dispute without appearing reckless of health and safety. There is a third case where you might need an MSDS. As I say, finished cosmetic products are exempt. But this is not a fact that is that widely known. Port officials in particular, are often under the impression that they are needed. It is not unknown for cosmetic products to be held up until this documentation is available. You do of course have the option of arguing the case with the officer in question. Good luck with that. But it is generally easier just to give them what they want.
And finally, retailers and distributors sometimes request them. The customer is of course, always right. There isn’t really any strong case that they need them either legally or practically. But if they think they do, it’s usually going to be a lot easier to simply give them what they want. It is a lot quicker than trying to argue, and it leaves them free to do more productive things like signing your cheque.
So having established that sometimes you need them, what are they? Basically they only make sense in the context of the overall way health and safety is managed in the modern world. The idea is that every process that is carried out is assessed for the risks it might pose. As part of that overall process it is necessary for people to assess the risk of handling the chemicals involved, both if things go according to plan or if things go wrong. The material safety data sheet is the means by which the professionals involved with assessing risk get the data they need on the chemicals they have to handle. So the MSDS should list every risk in every conceivable circumstance that could arise when you are using that material.
In a perfect world, I think the best way to do this would be for a well informed person to sit down and pen a thoughtful essay weighing up the possible dangers a particular material poses. I have actually seen such things. Despite their reputation for the exact opposite, scientists are often very good communicators and a well written description of something that the author knows well can be very informative.
But in the real world not everyone speaks English, not everyone has the time and also MSDS sheets are used differently by different people. So it is necessary to standardise them so that you can find the particular bit you need quickly, and in the form you are used to using it.
So a standard format has been agreed. This standard is somewhat convoluted. There are 16 sections that need to be filled in. Some of them are self explanatory, but many require the use of codes and standard phrases which are officially defined. Several sections overlap so exactly the same information gets listed several times. The whole process has become so involved that I found it necessary to get the standards out and carefully work through all the sections and details.
Having done so, I have decided I may as well share it with the world so I’ll be compiling it into a short modestly priced e-book. In the meantime I am under no illusions that the vast majority of material safety data sheets the circulate in the cosmetic industry – I alone have around 2,500 on file – are never read by a single soul. It’s a bit of a shame really.
Having said all that, we offer an MSDS writing service for finished cosmetic products if you don’t have the time or the inclination to do it yourself.