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Technical Writing: Hazard Communication Enriched

T.R. Girill Technical Literacy Project leader, STC and LLNL

T. R. Girill
Society for Technical Communication/Lawrence Livermore National Lab.

Technical Writing: Hazard Communication Enriched

The Change

Most science teachers are familiar with Material Safety Data
Sheets (MSDSs), summaries of chemical hazards loosely standardized
in the U.S. Code of Federal Regulations in 1994 (29 CFR 1910.1200).
On March 26, 2012, the U.S. Occupational Safety and Health
Administration revised this influential standard. While these changes
are gradual (rolling out over the next three years), they are also
* Coverage:
The new rules apply to about 945,000 chemicals, handled by employees
in about 7 million workplaces. Many people will therefore encounter
the new "Safety Data Sheets" (SDSs) and their associated chemical
* Consistency:
Different chemical suppliers interpreted the old rules differently,
so many MSDSs were incomplete, confusing, or inconsistently
organized. Now, the same 16 rows must always appear in the same
numbered order on every SDS (student-relevant example below).
* Labels and Classification:
For the first time, hazard communication in the U.S. has embraced
the grandly titled "Globally Harmonized System" (GHS) already used
in the European Union and Japan. Significant GHS features include
three that are also strongly reflected in the new Common Core
State Standards for learning effective technical communication:

1. Descriptions.
These must now cover responsible chemical sources (company name,
address, and even emergency contact number) as well as specific
biological hazards (e.g., "May cause liver and kidney damage").

2. Instructions.
These must now enable safe interactions (e.g., "Wear protective
gloves" or "Use only nonsparking tools").

3. Text/graphics integration.
To focus attention on hazards and to improve label usefulness
across different language communities, GHS labels supplement words
with standardized pictograms (for example, a stylized flame if the
labeled chemical burns).

The Opportunity

Living through a major standards shift like this can be
annoying. But it can also be a great opportunity--to build basic
student writing skills as well as to pursue key Common Core
learning goals. Such a change "means an authoring avalanche is
about to hit," explains safety consultant Jason Massey ("Global
Harmonization System Adoption," Professional Safety, March 2011,
p. 71). Commercially, companies will turn to SDS database vendors,
who will employ army of chemists to draft complete and compliant
descriptions. Academically, your students can mimic this work
for an authentic exercise in text design and revision that has
practical, high-stakes consequences.

Applying basic usability principles to safety messages can

* criticizing currently weak Safety Data Sheets--for instance,
these two for ammonium nitrate (they omit or trivialize the
SDS sections not mandated by the pre-2012 standards):

* designing better alternatives--by balancing completeness,
relevance for the different tasks and audiences addressed in
each SDS section (row), and clarity for reliable reading when
a problem occurs.

* explaining WHY their alternative text really improves the
original, feature by feature for each audience--a nice
exercise in argumentative analysis (another key Common Core
nonfiction communication goal).

Safety Data Sheets are self-scaffolding. They have more
visual cues and more overt structure than a science abstract or
a technical report. But otherwise, they expose students to all
the same writing decisions and content-management moves. You
can point out, for example, how a helpful Safety Data Sheet
includes (while an unhelpful one omits) section 13 on disposal
information. This added content really comprises disposal
INSTRUCTIONS (not just descriptions) because how-to information
is just what the audience for section 13 needs. And finally,
simply using a standardized section number, row format, and row
location enables rapid retrieval of these disposal instructions
during a chemical crisis.

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