Rudimentary forms of safety data sheets (SDSs) have been available since the 19th century. Some experts trace their history even further back to hieroglyphics found inside the Egyptian pyramids regarding the effects of various chemicals. But the modern SDS is a relatively recent invention, appearing a little over 50 years ago, with the first regulatory requirements adopted by the former Bureau of Labor Standards for the maritime industry, some 20 years before OSHA was created.
Today, OSHA's Hazard Communication Standard (29 CFR 1910.1200) regulates the use of SDSs. The standard requires you to obtain copies with incoming shipments of hazardous chemicals, to ensure that SDSs are readily accessible to employees during each work shift, and to make sure workers understand the safety and health information contained in this indispensable document, which OSHA calls a "one-stop resource for everything you might need or want to know about a chemical."
Complete, Accurate, and Clear
Since SDSs are really the backbone of the Hazard Communication Standard and your hazard communication program, it's important to make sure they're complete, accurate, and clear. To that end, you should:
- Audit the SDSs used by your employees to be sure they are complete and comply with OSHA requirements. Remember, required information includes:
- Material identification
- Identity of hazardous ingredients
- Physical/chemical characteristics
- Fire, explosion, and reactivity hazard
- Health hazards and first aid
- Precautions for safe handling and use
- Control measures
- Double-check with your safety director or the chemical manufacturer if you have questions about information contained in an SDS. The standard says that the manufacturer or importer who prepares the SDS must "ensure that the information recorded accurately reflects the scientific evidence used in making the hazard determination."
- Review sheets in your inventory and "translate" technical jargon that makes the SDS difficult for users of all educational levels to understand, or ask that the manufacturer or a specialty safety consultant do this for you.
- Consider the needs of employees who don't read or understand English. Although OSHA only requires that SDSs be in English, the law also says you must ensure that workers know how to obtain and use information on SDSs and chemical labels. One solution is to have bilingual employees on each shift who can translate relevant SDS data. Better still-especially if you have a lot of non-English-speaking employees-have your inventory of SDSs translated. If you opt for the second solution, be sure to choose a translator or service that specializes in technical safety information.
Access Is Essential
In addition to content, you also have to be concerned about access. Employees must always be able to get their hands on the SDSs they need. This means that whatever SDS management system you use-paper or electronic-it must be functional and available at all times.
If you maintain a paper file, make sure it's easily accessible and that employees know where to find it.
If you use an electronic system, OSHA says you must make sure there are "no barriers to immediate employee access." For example, if your SDSs are on CD-ROM or your company's intranet, failure to provide computers and/or computer training to employees would be considered a barrier to access and, therefore, subject to citation by OSHA. Similarly, if you use a fax service to provide SDSs, failure to provide immediate employee access to a fax machine or to train employees how to contact the service would be a violation of the standard.
Another important issue: If you normally rely on an electronic system, anticipate emergency situations, and make sure you have a backup system, such as a paper file, to ensure access in case the electronic system fails.
Time for Review
Of course, providing SDSs is only half the story. The other half is that your employees actually have to use them. One way to help instill the habit of actively using SDSs is to hold refresher training on the different hazardous chemicals employees work with-and to make the SDS for each chemical the centerpiece of the training session. There are plenty of reasons to justify such a session:
- A new chemical is introduced into the workplace (or a familiar chemical from a different manufacturer).
- A new use or process for a chemical is introduced, requiring new or different safe work procedures.
- A new SDS form-either a different format, or revised information-comes into the workplace.
- New employees entering the workforce may not be familiar with a chemical and safety rules for using it.