OSHA likes the idea too–as long as employees have immediate access. “Immediate access” means that, in emergencies, the MSDS should be available during the workshift when it was requested. In nonemergencies, it should be available by the next workshift at the latest.
Your electronic MSDS system 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 MSDS 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 MSDSs. That means you need to be certain the supplier provides complete, accurate, and up-to-date MSDSs without fail.
- Compatible with your computer systems. Whatever electronic MSDS 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 MSDS system, all employees who need to use MSDSs 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 MSDSs 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).
Testing and Backup
Don’t forget about testing and backup systems. If you use any kind of electronic MSDS system, it has to be tested regularly to make sure everything is working properly and employees are having no trouble accessing the MSDSs 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 MSDSs 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 MSDS 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.