OSHA’s Hazard Communication Standard requires you to have an MSDS for every hazardous chemical in your workplace, ensure employee access to MSDSs, and train employees to use them effectively to protect their safety and health.
Rudimentary forms of the material safety data sheet (MSDS) have been available since the 19th century. Some experts trace their history even farther back to hieroglyphics found inside the Egyptian pyramids detailing the effects of various chemicals. But the modern MSDS is a relatively recent invention, appearing just under 60 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 MSDSs. The standard requires you to obtain copies with incoming shipments of hazardous chemicals, to ensure that MSDSs 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.”
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Complete, Accurate, and Clear
Since MSDSs 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.
That’s why it’s a good idea to audit the MSDSs 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 the chemical manufacturer if you have questions about information contained in an MSDS. The standard says that the manufacturer or importer who prepares the MSDS 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 MSDS difficult for less educated users to understand, or ask that the manufacturer or a specialty safety consultant do this for you.
Also be sure to consider the needs of employees who don’t read or understand English. Although OSHA only requires that MSDSs be in English, the law also says you must ensure that workers know how to obtain and use information on MSDSs and chemical labels. One solution is to have bilingual employees on each shift who can translate relevant MSDS data. Better still—especially if you have a lot of non-English-speaking employees—have your inventory of MSDSs translated. If you opt for the second solution, be sure to choose a translator or service that specializes in technical safety information.
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In addition to content, you also have to be concerned about access. Employees must always be able to quickly and easily get their hands on the MSDSs they need. This means that whatever MSDS management system you use—paper or electronic—it must be functional and available at all times, on all shifts.
If you use an electronic system, OSHA says you must make sure there are “no barriers to immediate employee access.” For example, if your MSDSs are on a CD 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 MSDSs, 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.