Understanding and Accessing SDSs

Hóa chất độc hại; químico peligroso; खतरनाक रसायन. Would you be able to read a safety data sheet (SDS) in Vietnamese? Spanish? Nepali? Yet, environment, health, and safety (EHS) managers are required to maintain SDSs only in English. But, there is a hitch.

Do Your Workers Understand the SDS?

Under the Hazard Communication Standard (HCS), SDSs must be provided and maintained in English. The hitch here is that under the requirements of the HCS, you must make sure that your workers understand their training. And understanding SDSs is part of the training for hazard communication. If your workers do not speak English and are given work instructions in a foreign language, the training must be provided in that language. By the same token, if any of your workers have low literacy, training must be provided so they can understand it (e.g., verbal instruction vs. reading documents).

Although you are not required to have SDSs in other languages, a reasonable effort must be made to inform all workers of the hazards in the workplace. You must ensure that information from the SDS is available to employees in a manner they would understand easily in case of emergency.

The SDS may be translated into other languages that workers speak to aid in comprehension and training.

While the manufacturer, importer, or distributor is responsible for creating the SDS, in the United States, they are required to offer them only in English. That does not mean that they have them only in English. You can provide SDSs to your non-English speaking workers by:

• Contacting the company that created the SDS to see if they have it in the language(s) you need. Many larger manufacturers also produce SDSs in other languages.
• If you contract with an SDS provider, inquiring if they have SDSs in the language(s) you need;
• Contacting your state regulatory authority. Some state agencies, such as Washington’s Department of Labor and Industries, provide assistance with translations in languages that are commonly spoken in the state.
• Translating them yourself; or
• Contacting companies that translate SDSs. A quick Google search will provide a number of these companies. Check with colleagues in your field for references.

Can Your Workers Access the SDS?

Workers must be aware of the hazards to which they are exposed, know how to obtain and use information on labels and SDSs, and know and follow work practices, including use of any protective measures referenced on SDSs and labels.

Note: If you are maintaining material safety data sheets (MSDSs) for products received before June 1, 2015, you must provide training covering the differences between MSDSs and SDSs and how to use the MSDS.

Remember, you must train your workers on how to access SDSs at your facility. If you use an electronic system, they must be trained on both that system and the backup system. If you use a computer for maintaining SDSs, you must ensure that your workers have sufficient computer skills to access SDSs stored on a computer.

Don’ts of SDS Access

Your workers must have unrestricted access to SDSs. You cannot require them to:

• Have to ask for the SDS by storing it somewhere inaccessible such as in a locked office; or
• Perform an Internet search to obtain or view an SDS.

Do’s of SDS Access

If you are maintaining SDSs on a company website or with an offsite Web-based SDS provider, you must ensure:

• All workers have adequate computer or fax access with no restrictions;
• There is a backup procedure or system in case the computer or fax is not working;
• Training is provided for accessing the SDS on both the computer and the backup system; and
• There is a procedure in place for workers to receive a hard copy of the SDS if they want and in cases of emergency for medical personnel. It is not acceptable to just provide the information verbally to medical personnel.