Thinking of going electronic for your SDSs? Many companies are doing away with cumbersome paper filing systems in favor of such electronic systems as online SDSs, CD-ROMs, customized databases, and fax-back systems. For many companies, this is a sensible, cost-effective way to go. OSHA's on-board with the idea as well--as long as there are no barriers to immediate employee access. "Immediate access" means that, in emergencies, the SDS should be available during the workshift when it was requested. In nonemergencies, it should be available by the next workshift at the latest.
|Why It Matters...
- SDSs are an integral part of OSHA-required hazard communication and an essential part of your chemical safety program.
- Electronic systems can streamline SDS storage and retrieval, making administration easier for you and access quicker and easier for employees.
- But remember, you are still ultimately responsible for compliance--which means ensuring accuracy of information, immediate employee access to SDSs, and a backup system in case your electronic system fails.
What to look for in an electronic system. Whichever electronic SDS system you choose, it should be:
- Reliable. Electronic systems must provide reliable access 24/7, if necessary. Even with a backup, you don't want a system that doesn't guarantee maximum reliability. Ask suppliers for references and then call to ask them about reliability and their overall satisfaction with the system.
- Easy to use. Check out any system you might be interested in to make sure it's easy to use. If it's too complicated, some employees may have trouble using it, and might, as a result, skip checking an SDS when they should. To combat this, have employees at different computer skill levels try the system out and give you their impressions before you purchase.
- Accurate. Even if you buy a program from a reliable supplier, remember, according to OSHA, you're the one who's ultimately responsible for the accuracy of the information your workers get from SDSs. That means you need to be certain the supplier provides complete, accurate, and up-to-date SDSs without fail.
- Compatible with your computer systems. Whatever electronic SDS system you choose has to be compatible with your hardware and software. Otherwise, you could be looking at expensive upgrades or crippling technical problems.
- Cost-effective. Compare the cost of maintaining a paper filing system with the cost of an electronic system. Are you going to be saving any money? If not, is the extra expense justifiable in terms of efficiency, speed, and improved employee access to essential safety information?
- Accessible to all employees who need it. If you use an electronic SDS system, all employees who need to use SDSs must have access to computer terminals or other necessary equipment and must be trained to use the system and the equipment correctly. If the terminals aren't right there in the work area, and if all the employees who use SDSs haven't been trained in the electronic system, you're not meeting OSHA's immediate access requirement and are in violation of the Hazard Communication Standard (29 CFR 1910.1200).
Don't forget about testing and backup systems.
If you use any kind of electronic SDS system, it has to be tested regularly to make sure everything is working properly and employees are having no trouble accessing the SDSs they need. Even if your electronic system is working perfectly, according to OSHA Directive CPL 02-02-038, you still have to have a backup system to provide SDSs in the event of a system failure. Another electronic system can serve as a backup as long as it is not subject to the same problems as the primary system. For example, if a power outage will render your computer system inoperable in an emergency, you've got to have another reliable arrangement for contacting the chemical manufacturer, distributor, or other SDS provider (for instance, by cell phone) until your electronic system is up and running again. Otherwise, an on-site paper filing system may still be necessary as a backup.