Traditionally the intended readers of MSDSs were occupational hygienists and safety professionals. Now the audience also includes employers, workers, supervisors, nurses, doctors, emergency responders and workers. To ensure that MSDS users can quickly find the information that they need, the information should be in an easy-to-read format and written in a clear, precise and understandable manner.
For most people who work with controlled products, there are some sections that are more important than others. You should always read the name of the chemical, know the hazards, understand safe handling and storage instructions, as well as understand what to do in an emergency. Not necessarily. A lot of health hazard information, for example, is written in general terms. Your health and safety specialist, occupational health nurse or family doctor should be able to help you find more information if needed.
You should look at a MSDS, match the name of the chemical on your container to the one on the MSDS, know the hazards, understand safe handling and storage instructions, as well as understand what to do in an emergency. The format is left up to the manufacturer or supplier who writes the MSDS. However, the information for the nine basic categories must always be in a Canadian MSDS for a controlled product. If you are still using a product that you bought more than three years ago, you may not have a current MSDS.
Contact the manufacturer or supplier again and ask for a newer version of the MSDS. According to OSHA Recognize that this update requirement does not require the manufacturer to send a new SDS to you if you purchased a chemical prior to the SDS update. In other words, your SDS's will go out of date from time to time. It is a good idea to review your collection on a set basis and to update your sheets. What time frame to use is up to you.
The NTP updates its annual report on carcinogens each year, but perhaps longer is more appropriate depending on the nature of the materials and your business. You should consider setting a corporate policy on the matter. Those of you in Great Britain and presumably the rest of the European Union will be pleased to hear that CHIP requires the supplier to notify anyone who received the material in the previous 12 months if there is a change in the SDS.
In some countries, SDS's have expiration dates. Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options. The employer must meet all of the following requirements, however: SDSs must be readily accessible with no barriers to employee access.
This means reliable devices accessible at all times without the employee needing to ask anyone for permission. Workers must be trained in the use of these devices, including specific software. There must be an adequate back-up system and written plan for rapid access to hazard information in the event of an emergency including power-outages, equipment failure, on-line access delays, etc.
The system of electronic access is part of the overall hazard communication program. Employees and emergency response personnel must be able to immediately obtain hard copies of the SDSs, if needed or desired. The most popular types of electronic format these days are internet-based suppliers which usually operate on a subscription basis , and "in-house" solutions where corporations scan their SDS into a database rather than use a paper filing system. Other versions that are falling by the wayside in the Internet era are CD-ROM subscriptions renewable on a quarterly or annual basis and fax-on-demand services that will fax you a copy as soon as you request one.
Again, paperless compliance works only if the employees have " ready access ". If your database is accessible to the required employees on your corporate intranet, you'll probably be OK. This assumes that you have a written contingency plan to access SDS information in the event of a power failure or other emergency. Such a plan might include keeping copies on file or using a battery-powered laptop computer.
For on-line SDS subscriptions, OSHA will permit you to use a telephone as a backup system but not as a primary system instead of requiring you to have printed copies. See the next question and these two OSHA interpretations which discuss paperless compliance and "barriers" to access:. The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical , and shall ensure that they are readily accessible during each work shift to employees when they are in their work area s.
Electronic access, microfiche, and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.
What constitutes "barriers"? Quoting OSHA again:. Employees should not have to ask for an SDS, as this could be perceived by employees as a barrier to access. For instance, if an employee must go through a supervisor to receive an M SDS, the employee may feel that this singles him or her out.
This could very well dampen the employee's resolve to seek out necessary hazard information. There is no specific time limit used to determine whether an access barrier exists.
The OSHA inspector will interview your employees to ensure that they have "ready access" to the SDS's and have been trained on the chemical hazards in their workplace. Full compliance means that every employee that uses hazardous chemicals in the workplace or who could be expected to be exposed in a "foreseeable" emergency has " ready access " to an SDS.
In the context of The Hazard Communication Standard , serious violations involve hazard classification , written Hazard Communication programs , labeling , and no or inadequate training. Serious SDS violations include :. Willful violations are issues the employer should have been aware of based on previous inspections or workplace communications and deliberately chose not to abate.
And in all cases, these various penalty amounts are per violation , meaning one workplace could have dozens of violations during a single inspection. As of , most SDS violations have been substantially lower than the maximums given above. You might simply get a warning if you have only a few minor infractions. See this OSHA interpretation letter from for more information.
It depends. The HazCom standard is a performance-based standard which means that OSHA does not concern itself with how you comply, just that you manage to do it. While your method of managing your SDS collection is flexible, specific criteria you need to meet are:. See the ready access question above for more about "readily accessible" and what an OSHA inspector will look for in determining compliance.
This topic is covered explicitly in paragraph e 2 of Each contractor or employer has a responsibility to make sure the hazards of their chemicals and, therefore, SDS's are known to all workers on the site. See the OSHA interpretation, HCS training for employees contracted to jobs working under the supervision of another employer , for additional information.
The HazCom standard is performance-based meaning that OSHA does not care how the employers share this information as long the employees have no barriers to accessing the information when they need it and the plan for sharing this information in writing. The simplest solution for the multi-employer workplace is to provide each other copies of the SDS's or to add your SDS's to their collection as long as your employees have access.
Of course, other training , labeling etc. That means OSHA is not concerned with how you organize your SDS files, only that you " ensure that they are readily accessible during each work shift to employees when they are in their work area s ". This can be by hardcopy, computer, internet subscription, fax etc.
See this OSHA interpretation for more info. For an electronic system using an SDS software program or on-line service , organization is not really an issue as employees can call up SDS's using various criteria such as chemical name, CAS Number , or chemical formula. But for those of you who simply file paper copies, how to order your filing cabinet or 3-ring binder is a more difficult question.
Again, OSHA doesn't care how you choose to do it, but employees have to be able to find the information when they need it. For this reason, many people prefer to file their SDS's alphabetically by name. The biggest drawback to this is that one person might call a particular chemical " acetone " and another might call it "2-propanone". Both are synonyms for the same chemical compound. We therefore suggest that you train your employees to file by the name listed on the container label.
If you are into overkill, for each chemical synonym listed on the SDS, make a new page with that name as the title and write a note on it such as "see the SDS for acetone". Another popular method in chemical laboratories is to file SDS' by molecular or chemical formula. The standard convention is to list carbon and hydrogen first, followed by the other chemical elements in alphabetical order.
If there is no carbon in the compound, then simple alphabetical order is used. The drawbacks here are that not all materials have chemical formulas such as cleaning agents , and this system is more difficult for non-chemists. Every case is different and we really don't feel comfortable from a legal and moral standpoint trying to address such a complex issue. Hopefully, the points raised in this document will give you an idea of the parameters involved.
Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules.
Also, from time to time we update our guidance in response to new information. Gary W. Bird, M. The HCS is based on a simple concept - that employees have both a need and a right to know the identities of the chemicals they are exposed to when working and the hazard associated with them.
They also need to know what protective measures are appropriate to prevent adverse affects from occurring. The HCS is designed to provide employees with this information ultimately for the reduction of the incidence of chemical source illnesses and injuries.
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