Accuracy of Reported Flash Point Values on Material Safety Data Sheets and the Impact on Product Classification

Abstract

Material Safety Data Sheets (MSDSs) are the foundation of worker right-to-know legislation for chemical hazards. Suppliers can use product test data to determine a product's classification. Alternatively, they may use evaluation and professional judgment based on test results for the product or a product, material, or substance with similar properties. While the criteria for classifying products under the new Globally Harmonized System of Classification and Labeling of Chemicals (GHS) are different, a similar process is followed. Neither the current Workplace Hazardous Materials Information System (WHMIS) nor GHS require suppliers to test their products to classify them. In this project 83 samples of products classified as flammable or combustible, representing a variety of industry sectors and product types, were collected. Flash points were measured and compared to the reported values on the MSDSs. The classifications of the products were then compared using the WHMIS and GHS criteria. The results of the study indicated that there were significant variations between the disclosed and measured flash point values. Overall, more than one-third of the products had flash points lower than that disclosed on the MSDS. In some cases, the measured values were more than 20°C lower than the disclosed values. This could potentially result in an underestimation regarding the flammability of the product so it is important for employers to understand the limitations in the information provided on MSDSs when developing safe work procedures and training programs in the workplace. Nearly one-fifth of the products were misclassified under the WHMIS system as combustible when the measured flash point indicated that they should be classified as flammable when laboratory measurement error was taken into account. While a similar number of products were misclassified using GHS criteria, the tendency appeared to be to “over-classify” (provide a hazard class that was more conservative). So the transition to GHS may potentially decrease the possibility of “under-classifying” flammable and combustible products where no test data on the product are available.