Making MSDSs Universally Understandable
With the right system, the HazCom Standard that was designed to protect our workers may finally succeed in doing so.
- By Matthew Pullen
- Jul 01, 2003
WITH an estimated 650,000 hazardous chemicals in the workplace, tens of thousands of chemical manufacturers creating material safety data sheets, and a vague OSHA standard defining its framework, we are left with a discombobulated mess of MSDSs. Yet we are required by law to maintain them in the workplace for our employees.
To the average worker, a material safety data sheet is a complicated document that he or she needs to be able to locate in an emergency or during an OSHA audit. Compliance is typically maintained by stuffing the MSDS into a binder that may or may not be accessible, orderly, or even legible once located.
Some businesses have taken a more advanced approach to MSDS management by using software and/or Internet services that provide access to manufacturer-original documents. While they are practical and cost effective, these systems fail to address the basic issues surrounding MSDSs. They provide little use, if any, to the workers that the Hazard Communication (HazCom) Standard set out to protect.
The Root of MSDS Issues
The primary objective of an MSDS is to protect the worker in the event of unintended exposure to the chemical, but what good is an MSDS if he needs a Ph.D. to understand it? Aside from understanding the complex chemical terminology, there are other debilitating obstacles, such as deciphering the format, finding the appropriate section, interpreting the toxicological findings, and ascertaining the MSDS is in fact for the correct concentration or variation of the chemical.
Add in a worker with a learning disability or the chaos caused by a chemical accident. Now, how easily can the MSDS be read? This has created a negative attitude toward MSDSs in the workplace that has transpired since the inception of the HazCom Standard. A urethane supplier expressed this resentment of the regulation on its Web site by saying:
"Granted, nobody ever looks at these things, but some guy sitting in his air-conditioned office in Washington, D.C. has decided that you are required to keep these on file. He feels like he is doing his 'job.' Anyway, if some inspector is at your place asking to see copies of your MSDSs, we've got them here for you."
Downfall of the Scanned MSDS
Scanned MSDS solutions through software or online systems create a barrier to the worker by relying on his or her ability to find, interpret, and understand the formats of the chemical manufacturer's document. In addition, scans provide limited flexibility when regulations evolve into more stringent enforcement standards and requirements.
A prime example of this is Europe's use of Tremcards, a special format of written emergency instructions developed by CEFIC (the European Federation of National Chemical Industry Associations). This form must be provided in the native language of the driver and used during chemical transportation. A scanned MSDS is unable to facilitate the creation of a Tremcard because the needed content cannot be leveraged from the document. The software used to create the scanned image of the MSDS inadvertently "freezes" the information from being used by associated applications. As a result, Tremcards, container labels, personal protective summaries, and other ancillary warning documents require manual effort to produce.
The software used to "freeze" the MSDS for viewing, such as Adobe Acrobat Reader, is also required to view the scan. While this software is free for downloading, it creates a barrier due to the bulky Internet bandwidth of the scanned MSDS (up to 250 Kilobytes) and the PC memory requirements to run the additional application (approximately 33 megabytes of RAM).
Finding the Right MSDS System
In recent years, applications have become available from select Internet companies (ASPs) that solve compliance issues and provide a universally understandable MSDS for workers. These Web-based services are able to protect people from the mismanagement of chemicals by offering a variety of functions and features that not only allow access to MSDSs, but aid workers with understanding the information.
1. Ease of reading
A key factor is having a MSDS system that standardizes all documents into a consistent format, making them easy to read and, more importantly, navigate. The manufacturer's original may be available, as well, but for practical purposes employees with limited training cannot be expected to find information across a variety of formats and qualities.
A common challenge when it comes to keeping a facility compliant is making sure the MSDSs on hand are legible. A typical MSDS has been fed through a fax machine two to three times. Its quality has been severely degraded, and the burden to decipher the weathered, tarnished document has been left on the individuals who need it the most. Another challenge when dealing with a MSDS is the ability to navigate through the sections, finding the appropriate information pertaining to the nature of the inquiry.
MSDS compliance issues are not exclusive to the United States. The United Nations has recognized the need for such a system and recently adopted "The Globally Harmonized System for the Labeling and Classification of Chemicals" in Geneva after a decade of efforts and cooperation among a broad number of countries and organizations.
2. Full searchability.
Locating information within a MSDS or simply finding the correct one can be an arduous task for workers when they are uncertain of the chemical's specifics. Having the MSDS in a fully searchable format allows an employee with limited knowledge of a particular substance to use the characteristics he or she does know to find the MSDS for that chemical
A comprehensive word or term search throughout the entire body of text is vital to workers. Let's say a worker comes across a yellow liquid on the floor that has a pungent odor. How can he be expected to find the appropriate MSDS if the only search criteria he can use is the chemical's or manufacturer's name?
3. Dictionary reference and speech-enabling.
Understanding the information in the MSDS--once the worker finds it--can be facilitated with the latest dictionary reference system. This unique feature allows the worker to submit an unknown word or term at the click of a button to a dictionary containing more than 100,000 chemical definitions.
Considering that 92 million people have difficulty reading and another 42 million people are dyslexic, the expectation for workers to understand MSDS terminology is unacceptable. Newly designed MSDS applications further support those workers with disabilities, allowing MSDS phrases to be read out loud by the computer.
4. Labeling and training.
Besides mandating the MSDS, the HazCom Standard requires chemical containers to be appropriately labeled and employees to be trained in MSDS access and comprehension. Training times are significantly reduced using such a system, but many fail to address the critical issue of label application.
Because the information needed on the container label comes from the MSDS, some systems have integrated labeling programs that allow one-mouse-click printing of the appropriate label. These MSDS-generated labels include universally understandable pictograms, such as the NFPA diamond or HMIS barcode. This eliminates the need to find the "appropriate hazardous warning" from the MSDS and handwrite the information on the label.
5. Hazard classification.
Additional system capabilities include grouping or classification of chemicals based on reported hazard criteria in the MSDS. This can be a straightforward comparison with a federal regulatory list such as TSCA or an advanced screening, such as "a chemical with a flashpoint under 100 degrees Fahrenheit, is a liquid, and contains Methyl Ethyl Ketone." The classification criteria are limitless and provide information to safety managers for improving everyday job functions.
Chemicals are not always used next to the computer or cabinet where they are stored, so best-of-breed MSDS providers allow access to MSDS information through a variety of media and formats. These MSDSs are as much as seven times faster, require no hardware or software, and use industry-standard Web browsers (Internet Explorer, Netscape, and AOL). They allow MSDS data feeds and integration with ERP systems through XML and on-demand delivery to Personal Digital Assistant (PDA) Resources or a NextelÒ
phone through wireless application protocol (WAP) technology.
Having the flexibility of how, when, and where a worker can retrieve MSDS information lets the employer decide how its will perform with the HazCom Standard and can make the difference in a successful safety program.
Other groups have the need and legal right to MSDS access in the event of an emergency. Emergency medical responders, state and local emergency personnel, and the fire department use information contained in an MSDS during the assessment and resolution of chemical incidents. Recommended procedures and warnings contained in MSDSs help to maintain public safety and prevent loss of life. The technology behind various Internet text-based solutions allows for communication to remote systems utilized by emergency responders, such as laptops, wireless phones, and PDAs.
While scanned electronic systems help maintain OSHA compliance to the strictest sense by providing access to documents, what the majority of these systems fail to provide is a universally understandable MSDS with the capabilities to aid the worker and emergency personnel in comprehending the hazardous information and protective measures he or she will need to know in an emergency.
This article originally appeared in the July 2003 issue of Occupational Health & Safety.