Ditch the book. Which book? That “big honkin’ binder” out in the shop with all of your Material Safety Data Sheets (MSDSs).
While it is common knowledge that you need to have a copy of the MSDS for “any chemical which is known to be in the workplace in a manner that employees may be exposed,” it is not so well known that the copy need not be on paper. Any chemical to which an employee can be exposed must be identified, the hazards documented and communicated, and be accessible. But the means may be electronic.
So why ditch the book? Because the book is never up to date. Because the book can have sheets that are lost, removed deliberately or accidentally and not replaced. “Big honkin’” binders are not systems; they are compliance targets (especially in large shops where departmental or multiple binders might be present). Because putting papers in notebooks is never a reliable process.
The Hazard Communications Standard is the applicable regulation for MSDS maintenance. OSHA directive CPL 2-2.38D, effective date March 20, 1998, makes clear that paper copies are not your only option:
(g)(8) “MSDSs must be readily accessible and there must be no barriers to employee access during the work shift … the use of electronic means such as computers with printers, microfiche machines, the Internet, CD-ROMS, fax machines, etc. is acceptable.
“Employers may use off-site MSDS management services to meet the requirements of the HCS only if MSDSs are readily available to employees, either as hard copies in the workplace or through electronic means and as long as the provisions outlined in the previous paragraph are ensured.”
So why would you want to go to an electronic system for maintaining MSDSs? Better control, security and accessibility come to mind immediately. Better legibility, ease of finding, and ability to have open, multiple copies. Having a single authoritative repository (rather
than the office saying the shop book is complete and the shop personnel saying that the office files are more complete than the book in the shop).
Here are three considerations before making the move to electronic storage of your MSDSs.
First, you must ensure that the sheets or their alternatives are maintained in a place and condition where the employees can access them during each work shift, when they are in their work areas. So, if the only computer is in the office, and it is locked and separate from the employees, that will not work.
Second, your employees must know how to operate and access the system to obtain the information. If you go with an electronic system, you can expect to have an employee be asked to retrieve an MSDS when OSHA audits you. Training is important.
Third, you must create a process to ensure that each MSDS is scanned and filed. Purchasing is the key to making vendors responsible for providing MSDS information for all products to which employees may be exposed in the workplace. Improving this aspect of the process will pay dividends in both enhanced safety and inspection compliance.
While the OSHA inspection procedure says, “employees must have immediate access to MSDSs and be able to get information when they need it in order for an employer to be in compliance,” our discussions with OSHA indicated “during work shift” was the operant condition.
What are some best practices for electronic MSDS filing and maintenance?
1) All purchase orders must require an MSDS to be supplied with the first shipment of product. No exceptions.
2) All received MSDSs must be scanned as PDFs and filed on a server accessible to all employees.
3) Scanned PDF MSDSs can also be posted to an internal website and then linked for easy access by employees.
4) Those PDFs can also be emailed or synched to department iPads and maintained in iBooks.
5) Don’t forget that consumer products and raw materials used in the workplace may be considered hazardous chemicals requiring MSDSs on file.