To understand why information can vary, especially the different signal words that appear on these documents, I first have to discuss what these documents are used for and by whom.
First, it is important to understand that pesticide labels & label language are overseen by different government agencies than Safety Data Sheets (SDS).
Labels: Overseen by the Environmental Protection Agency under the direction of FIFRA (Federal Insecticide Fungicide and Rodenticide Act).
SDS: Overseen by OSHA (Occupational Health and Safety Administration) under the direction of the Occupational Safety and Health Act.
These different governing agencies have different requirements for these documents.
Most pesticide applicators and PMPs learn about signal words in their basic training. The signal words that can exist on a pesticide label are: CAUTION, WARNING AND DANGER POISON. These signal words help a PMP or end user identify the toxicity category the product has been assigned and also the general hazard the product poses.
To understand why SDS have different signal words from pesticide labels, it is important to understand a little history. In 2015, OSHA changed their standards to be in alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This means, globally, SDS are similar and provide similar information, regardless of where in the world you are.
One of the major changes was the signal words that could appear.
There are only two words used as signal words on SDS, “Danger” and “Warning.”
Signal Words are used to indicate the relative level of severity of the hazard and alert the reader to a potential hazard on the label. Within a specific hazard class, “Danger” is used for the more severe hazards and “Warning” is used for the less severe hazards. There will only be one signal word on the SDS no matter how many hazards a chemical may have. If one of the hazards warrants a “Danger” signal word and another warrants the signal word “Warning,” then only “Danger” should appear on the document.
The SDS is not intended for use by the general consumer or end user, instead it is for information pertaining to hazards associated with working with the material in an occupational setting such as manufacturing and shipping, not in an occupational setting related to an end user application. PPE requirements can also be different for occupational handling & manufacturing than for end user applications and handling and those can be reflected on the SDS as well.
Remember: PMPs should utilize the product LABEL not the SDS to determine the Toxicity Category.
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