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Include information from your hazard communication (HazCom) Plan. Your Hazcom Plan must describe the process for ensuring that employees have immediate access to SDSs. The description must include all the following information:
- The person(s) responsible for obtaining and maintaining the SDSs
- How they are accessed by employees
- How and where they are kept in the workplace
- Procedures to follow when the SDS has not been received
- A description of alternatives to obtaining SDS information (the backup system)
Describe your process for “immediate” access to SDSs. Make sure the Plan describes how employees can immediately obtain the required SDS in an emergency. “Immediately” generally means, in emergencies, during the work shift and in the work area of the person who requested the SDS; in nonemergency situations, by the next work shift after the SDS is requested. Reading SDSs over the phone is not an option, except when employees must travel between workplaces during the work shift and require the information in an emergency.
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Describe your SDS access backup system. If a fax-back service or computer terminal is your primary system, another electronic system may serve as a backup as long as it is not subject to the same barriers as the primary system. If a power outage will render the fax machine and computer inoperable in an emergency, make sure other arrangements to contact the chemical manufacturer, distributor, or other SDS provider by cell phone or other means have been made to obtain the SDS. Otherwise, an on-site paper filing system may be necessary. Either way, document the access procedure.
Document that your SDS access system works. Periodically test your primary and backup systems. Run through an emergency access scenario with your access provider and your employees. Record the results of SDS access system tests and put them with your written HazCom Plan.
Establish a multiemployer policy for accessing SDSs. A multiemployer worksite exists any time employees of different employers are on the same site (e.g., a cleaning crew comes into your workplace, or a welding contractor performs work). Also, any employer that hires the services of an outside contractor or vendor is responsible for ensuring compliance by the contractor with the requirements of OSHA’s hazard communication standard if the contractor exposes any employees at the site to chemical hazards.
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According to OSHA citation procedures for agency safety and health inspectors (CPL 02-02-038), if the controlling employer at a worksite uses a general contractor or other employer as an intermediary for storage of the SDS(s), and that intermediate employer has agreed to hold and provide ready access to the SDS(s), then the intermediate employer becomes the controlling employer, and is responsible for ensuring the availability of the SDS(s).
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