SDS Availability Must Be 24/7

By: Maureen Paraventi

It’s not enough to have a safety data sheet (SDS) for each hazardous chemical in your workplace – one that describes the physical, health and environmental health hazards of the substance, and provides information about how it should be safely handled and stored. Employers must make sure that employees are able to access the SDSs they need, around the clock, during any shift.

That was one of the points emphasized by Phil Molé, during a presentation entitled, Avoiding Incompatible Chemicals: HazCom Tips for COVID-19 and Beyond, during VPPPA’s 2021 Next Level Safety event in April 2021. Molé, who is Environmental Health & Safety (EHS) and Sustainability Expert at Velocity EHS, brings 25 years of EHS experience to the subject.

Most chemical manufacturers, distributors and importers understand the importance of having SDSs, which are required under OSHA’s 2012 revision of the Hazard Communication Standard (HazCom) (29 CFR 1910.1200(g)). Formerly known as MSDSs or Material Safety Data Sheets, SDS have much of the same information as MSDSs, but in a 16-section format OSHA describes as more “user-friendly.” Keeping SDSs available to all relevant employees can be problematic in the best of times, but Molé said the pandemic has made it even more challenging at some facilities, particularly those who were using physical, on-site SDS information stations or have workforces that are geographically separated. In response to the pandemic, some companies closed or restricted access to certain areas, or moved workstations in order to increase the distance between employees.

“We may have people who are not in the usual locations they work in,” Molé said. “If we don’t have ways that people can access SDSs from anywhere, then we’re not meeting our obligations under the standard. Remember: there can’t be any barriers to access.”

Even if SDSs are in digital, rather than physical form, getting to a computer may prove difficult. “If they’re in a supervisor’s office and that door is locked when he or she goes on a lunch break, then we’re not meeting our obligations because that barrier is keeping employees from accessing that information.”

He noted that companies must be able to print hard copies of the SDSs upon request. If the SDSs are online, there must be a backup system in place, in case of an emergency. A cloud-based SDS system is fine – as long as employees know how to do it. Companies should not advise employees to “Google it” when looking for chemical hazard information. Molé said a 2015 OSHA interpretation letter sent in response to a query from a company made it clear that an online search was not acceptable under the regulation. “There is no guarantee – and very little chance – that they’re going to find the documents for your chemicals that are in your locations,” he said.

HazCom Responsibilities

In addition to discussing SDSs and Right-to-Know access, Molé outlined other HazCom responsibilities of employers who are the end-users of chemicals. They include:

  • Having a written, site-specific HazCom plan for their chemicals, their hazards and their methods of providing access to safety data sheets to their employees.
  • Compiling a chemical inventory list.
  • Implementing a management method for labels, including both shipping labels and secondary container labels.
  • Training employees about the general requirements under the HazCom standard, as well as all of the specific aspects of HazCom management at the facility.

As for the last item, Molé said it’s a good idea to make sure that every employee can recognize the HazCom pictograms that OSHA requires on labels for hazardous materials. The skull and crossbones pictogram, for instance, indicates acute toxicity (fatal or toxic), while an exclamation mark warns of a whole range of dangers, from skin, eye and respiratory tract irritation to an environmental effect: hazardous to the ozone layer.

To illustrate the importance of compliance with the HazCom standard, Molé told a story from when he was a graduate student and had to go to a hospital and listen to cases of people coming in to talk about their previous work experiences and how those affected subsequent conditions and health problems.

Of the many people he met while doing that, “there was one gentleman whose story I never forgot. His job, for 35 years, was to take greasy parts and dip them in a tank that was filled with solvent. He did this by hand, and he did this repeatedly, every day for 35 years. Because there was no HazCom standard for most of the time he had this job, he did not even know the identity of the chemical he was working with, so he definitely didn’t know the right precautions, like what type of ventilation was adequate, what types of personal protective equipment he needed or how he should be storing and using this chemical on a day-to-day basis.”

The solvent contained a chemical that – in the case of long-term exposure to it – caused brain damage, including short-term memory loss.

“It became evident during this interview that while he could remember all of these details from the past, he couldn’t remember how he got to the interview that day,” said Molé. The man’s wife, who was with him, was evidently his caretaker as well. He was unable to live independently because of the chemical exposures that he’d had.

“That’s really the reason why all of these regulations and requirements exist. It’s not just a bookkeeping exercise we have to do,” said Molé. “It’s not just a matter of compliance. These things are important because employees need them to be able to get home safe at the end of every day.” WMHS

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