Surfing the Internet for MSDSs

Are you managing your MSDSs electronically? Why not?

THIRTY-two million workers (roughly 10 percent of our population) are potentially exposed to an estimated 650,000 hazardous chemical products each day in more than 3 million American workplaces, according to recent OSHA statistics. Having a solid safety program helps keep your employees from being a statistic. Safety is a major concern in most businesses across the country, and the management of Material Safety Data Sheets (MSDSs) is a critical part of the safety equation.

There are many things safety professionals need to do in order to stay compliant with various regulations. Maintaining a current database of MSDSs for chemicals used in your facilities is not only a requirement by OSHA, but also vital to ensuring the well-being of your employees. This is especially complicated if your company uses hundreds, even thousands of chemicals. Then, the task of managing MSDSs and meeting compliance regulations can be daunting.

Enter the Internet. The Web has ushered in many business-to-business applications that deliver on the promise of access, speed, and efficiency over the traditional paper-based processes of the past and has begun to revolutionize the EH&S industry.

Why Not Stick with Paper?
Put simply, paper-based MSDS management systems are costly, cumbersome, and require time and resources that otherwise could be deployed on other more important safety issues.

Consider the time you or your employees spend requesting MSDSs from your suppliers and distributors, managing all of the various versions and revisions, matching MSDSs with the appropriate locations and workstations, managing multiple binders, and so on. This sort of mundane paper work takes valuable time away from other more important safety tasks and business issues. In fact, a recent study suggests EH&S professionals spend 78 percent of their time each day completing tedious compliance reporting and record management tasks.

On the surface, managing MSDSs on paper may seem inexpensive; however, industry estimates suggest that paper-based systems can cost as high as $15 per MSDS document per year. Think about how many documents you manage in your facility. Couple that with potential lost production time, worker's compensation claims, non-compliance penalties, and possible litigation fees, and it becomes very clear why more and more companies are implementing electronic MSDS management systems.

Is Electronic Management Compliant?
Obviously, compliance is one of the most important things to consider when talking about an MSDS management program. Non-compliance with the Hazard Communication Standard (which includes MSDSs) is among the most frequent violations cited by OSHA. With OSHA fines in the tens of thousands of dollars, it's important that you understand how to keep your company safe while being compliant.

The HazCom Standard (1910.1200) requires employers to "ensure that MSDSs for all hazardous materials at the facility are readily accessible to employees while in their work areas." OSHA's biggest concern is that you meet its requirements and follow regulations. It doesn't regulate how you manage your system. Electronic management is not only compliant, it is the best way to manage your MSDSs--provided you have a back-up means of accessing MSDSs should you have a power outage or other emergency. And quite frankly, you should have a back-up plan in place, regardless of how you are managing your MSDSs.

All of these regulations and standards can seem like a headache, but you can't forget the reason they exist. Regulations are not put into place to make you spend money and waste time. They are designed to help you keep employees safe and lower your risk of accidents or personal injury resulting from inadequate communications around potential hazards. To further complicate things, MSDSs or exposure records need to be kept on site for 30 years. Unfortunately, many companies often find this out when being faced with litigation proceedings from a former employee who has a life-threatening illness as a result of exposure to a hazardous product in the workplace.

Frequently, MSDSs play a critical role in this type of lawsuit, and the inability to produce such records can have detrimental consequences for your business. In general, a good electronic MSDS system will make your company more compliant with all of these requirements.

Electronic vs. Paper Management
It has become increasingly popular to move from paper-based systems to computer-based or Internet-enabled systems. Companies are quickly realizing a return on investment and more compliant MSDS programs by using well-designed electronic systems that reduce both hard and soft costs around managing MSDS. Not only do these systems satisfy OSHA's "readily accessible" requirement, but, in the case of Internet services, they also afford instant access to MSDSs and decrease the likelihood of serious injury or illness.
One of the main arguments against paper-based management is that documents can be indexed and thus searched by only one keyword (e.g. a product name, manufacturer, date or an internally assigned product code, etc.). Consequently, once an index is created, it is possible to locate a specific MSDS only by that keyword unless a cross-index is created and maintained.

Electronic MSDS management provides multiple indexing capabilities and enables users to search based on numerous fields, thus making it easier to locate an MSDS in a timely manner and reducing risk and liability. Such implicit cost benefits may not be initially apparent but, should an incident occur, they could very well be the most valuable.
Version management is another benefit of an electronic MSDS management system. Consider how much easier and more cost effective it is to simply search and replace an MSDS in one place than to have to go to multiple binders or filing cabinets to accomplish the same task manually with paper.

The savings gained from the reduction of MSDS administration time with an electronic system are probably the most obvious benefits. Using the estimates mentioned earlier, an inventory of 5,000 MSDSs would cost a company upward of $125,000 annually to manually maintain and deploy. Moreover, it's virtually impossible to monitor how current your MSDS inventory is using a paper-based system. Furthermore, think about how many times an MSDS is misfiled or lost, necessitating a replacement. An electronic system that's tied to a large MSDS database will allow for almost instantaneous updates or replacements with considerably less time and effort.

Employer Guidelines Set by OSHA for Electronic MSDS Management

1. The employer must ensure MSDSs are readily accessible and there are no barriers to employee access. This includes ensuring reliable devices are readily accessible in the workplace at all times.

2. The employer must ensure workers are trained in the use of these devices, including specific software.

3. The employer must ensure there is an adequate back-up system for rapid access to hazard information in the event of an emergency, including power outages, equipment failure, online access delays, etc.

4. The employer must ensure the system of electronic access is part of the overall hazard communication program of the workplace.

5. The employer must ensure employees are able to obtain hard copies of the MSDSs, if needed or desired.

6. In case of emergency, the employer must ensure mechanisms are immediately available to provide emergency response personnel with hard copies of MSDSs.

Which Electronic System is Best for You?
When choosing an electronic system, you should think about the capabilities you are looking for and understand the difference between the types of systems that are available. Generally speaking, there are two primary options: Internet-based services and software-based systems.

Internet-based services are popular because they often provide immediate access to large databases of MSDSs. Look for providers that continuously add new or updated MSDS content. Beware, however, of sites that claim large databases but simply contain links to out-of-date databases or reroute you to other Websites that are often difficult to access and sometimes password-protected.

Finding an Internet-based service that has one-stop access to MSDSs is imperative. Look for a site that houses a large and comprehensive database, updates it regularly, and has a customer service team that will help you implement the system every step of the way. Also, make sure the system includes back-up capabilities so you are compliant. Why not get everything you need from one source?

Having access to MSDSs is only half the battle in terms of compliance. You need a way to manage your inventory, making sure it's up-to-date, relevant and easily accessible to employees. When scouting out Internet-based MSDS services, it's important to understand the extent of their MSDS management capabilities. What kind of reporting tools are available? Can you organize and manage site-specific inventories? How are MSDSs deployed throughout the organization? These are all important questions to ask when exploring an Internet-based MSDS management system.

Software-based MSDS management systems are another electronic option. These systems share a number of advantages with Internet-based systems in terms of quicker search and retrieval and simplified MSDS management. And some offer a wider range of management tools. The pitfall is that some software-based systems come with no database or a pre-populated database of MSDSs that are static and not site-specific. In other words, it is unlikely they contain the MSDSs you need. If they don't, it's more difficult and costly to add your uniquely required MSDSs.

In fact, most software systems require the user to enter the information for all of their MSDSs. Beyond the challenge of building the initial database is the one of having to keep the database up to date. Users of pure software-based systems often complain about the high cost of ownership for this type of system. They either have to invest in resources to scan, upload, and re-key all the information or have to pay more to have the database updated each year.

Final Tips Before You Buy
First, make sure the system you choose meets OSHA compliance requirements for an electronic system. The key here is to make sure the system provides a backup capability. If you're looking at Web-based systems, make sure you have local backup capability, giving you to ability to access your MSDSs in the case you can't access the Internet.
Look for systems that provide dynamic databases to ensure you always have access to new or updated MSDS versions. Also, look for a provider that offers both "do it yourself" options and a services component to help you build and maintain your inventory. This keeps you in control of your inventory and provides flexibility to add MSDSs when you need to.

Safety isn't just in numbers. Users should look for a system that not only provides a large MSDS database, but also one that ensures consistent, reliable quality of those documents. MSDSs should always be current, and the service should be frequently updating MSDSs to guarantee the most accurate, up-to-date inventory.
It is important that all of the documents are manufacturer originals (re-keyed MSDSs take the liability off the manufacturer and, unfortunately, put it in your hands), whether you choose an online or software solution.

When looking at Internet-based systems, ask about security because MSDSs and the related information may be considered proprietary information for many companies.
Companies are constantly expanding, adapting, and facing new challenges. Don't forget to ask yourself whether the system you purchase now will grow as your company grows. Look for systems that are flexible and offer different levels of service at corresponding prices.

Most importantly, make sure you choose a system that is easy to use, both for those who are responsible for administering the MSDS inventory and for your employees. If the system is not intuitive and requires a lot of extra training, it won't get used.

Finally, when choosing an electronic MSDS solution, make sure you own your MSDSs and associated data. Unfortunately, some systems don't enable users to export their data in the event they need to change vendors or go in a different direction.

Research your options. Fortunately, there are many to choose from, and you're sure to find a system that meets your unique requirements. Today, effective MSDS management and compliance is both achievable and affordable.

This article originally appeared in the June 2007 issue of Occupational Health & Safety.

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