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. Take a look at the previous question for some specific insights. The one recommendation we will make is that you maintain your paper copies. Beyond that, we'll also say that some organizations will find it very advantageous to utilize one of the " paperless compliance " services discussed in this document. But that's where our specific recommendations end, sorry. This makes sense when you consider the following:.
That said, you can use our SDS page and search engines or various Internet collections as a source to find the electronic and hard copies of SDS's that you need for your collection or to see if more recent sheets are available.
While SDS's are a necessary part of these requirements, merely making these available or distributing them to employees is insufficient. An employer's training program is to be a forum for explaining to employees, not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program.
This can be accomplished in many ways audio visual, classroom instruction, interactive video , and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them. Moreover, with the advent of the HCS adoption of the GHS system , you will need to train your employees on labeling, pictograms , and other key elements of the HCS. Yes and no. Paragraph g 2 of 29 CFR The same is true of label requirements. At first glance, it appears you do not need to make special provisions.
SDS's are part of the hazard communication process and training requirements; if your employees do not understand English and you do not provide training in a language they comprehend then you are not in compliance.
This statement includes the following:. In practical terms, this means that an employer must instruct its employees using both a language and vocabulary that the employees can understand. For example, if an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand. Similarly, if the employee's vocabulary is limited, the training must account for that limitation.
Every business is required to have a written hazard communications policy. Skip to main content. MSDS inventory list. Read more. Find msds sheets online. Msds index sample. If your business uses hazardous chemicals in workplace operations, you are responsible for ensuring that each hazardous chemical has a safety data sheet that is made accessible to employees.
For example, disinfectant products kept on hand for employees to disinfect their own work stations. On the other hand, safety data sheets are required for household consumer products that contain hazardous chemicals if employees are required to work with them more often or for longer periods of time than a regular consumer. For example, disinfectant provided for janitorial workers.
Both documents communicate information regarding hazards and safety precautions for working with hazardous chemicals. Safety data sheet authoring companies can provide this service, or it can be done internally with in-house experts e. If your business otherwise works with hazardous chemicals in a manner or quantity regulated by OSHA, it is your responsibility to contact your chemical supplier and request SDS copies. As of June most material safety data sheets should have been converted to SDS format.
There are 16 sections for any safety data sheet and these sections are further grouped into four categories: General Information, Technical and Scientific Information, Information Governed by Other Agencies and Other.
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