Using the Web to Simplify Compliance

MSDSs are only truly accessible if an employee can match the correct MSDS to the product with which he or she is working.

IN the world of hazardous materials, the Internet is the emerging tool of choice for providing material safety data sheets to employees and product purchasers downstream in commerce. Incorporated with an MSDS database, the Internet can be a cost-effective and efficient tool for Hazard Communication compliance and enhanced employee safety. It can enable you to maintain compliance by helping you obtain the MSDSs that you require and provide assistance in their management and distribution.

Simple concepts on how to use the Web to better manage your MSDS needs and simplify hazmat compliance are suggested below.

It is important to note that you should not blindly trust the content of all MSDS management Web solutions. Some supposedly free or low cost MSDS offerings--many of which were launched during the Internet boom of the late 1990s--claim to have thousands of MSDSs, direct from the manufacturer, available at no charge. In reality, because these Web sites have generated little revenue and maintain limited staff, chances are their MSDSs have not been kept current and are probably outdated.

Managing your MSDS
Once you have located your MSDS, you can also use the Internet to manage it, using an MSDS management tool hosted by a service provider. If you publish your own MSDSs, you can make them visible to the world via the Web. Hazard Communication-mandated MSDS distribution can also be conducted via the Internet, assuming customer acceptance is obtained in advance.

Internal MSDS management and employee access require conscientious MSDS obtainment and an organized information management process. For instance, a company that purchases a relatively small number of hazardous products from a limited number of vendors, who distribute their MSDSs reliably, could adopt a solution to scan or re-key their MSDSs into a master database system and then make the MSDSs electronically available over its corporate network or intranet. There would be some cost for the data entry, and you would need an efficient IT team, as well.

Alternatively, if you have a large hazardous materials inventory and you buy from hundreds of vendors instead of a few, you'll need to control the reliability of receiving the data you need. If each of your facilities handles its own procurement, will they all need dedicated staffing for data entry and MSDS database management? And if you use the Web for MSDS distribution, is your IT support available 24/7/365? These issues need to be addressed in order to maintain compliance should you choose to manage your own MSDS systems.

If you are a mid-sized company or larger, with multiple facilities and limited staff and dollars for MSDS management, you may want to consider outsourcing. Outsource service providers can significantly reduce your costs for MSDS management and distribution and simultaneously increase your level of compliance.

Using the Web to Debunk Popular MSDS Myths
The Internet also can be a valuable fact-checking resource for hazmat manufacturers, distributors, and importers. Conducting a thorough search of the OSHA Web site (www.osha.gov) dispels some of the most common myths about MSDS compliance and provides valuable feedback on how OSHA has addressed some of these issues in the past.

Myth 1: "There are only one or two approved formats for an MSDS."
It is perfectly acceptable and compliant for a hazmat manufacturer, distributor, or importer to develop an MSDS in any format that best suits its needs. This flexibility is even written into the standard. 29 CFR 1910.1200(g)(10) states that no standardized template is required when producing an MSDS.

However, each MSDS must have, at a minimum, enough data to allow an employer/employee to easily identify the product; determine the physical and health hazards of the material; and contact the manufacturer, distributor, or importer for additional information if necessary. OSHA offers a template for MSDSs on its Web site.

Myth 2: "Every shipment of a product must have an MSDS enclosed."
A manufacturer or distributor must include an MSDS the first time a product is shipped to a company and with the first shipment after the MSDS is updated or changed. Manufacturers/distributors often include an MSDS with each subsequent shipment to avoid tracking who has, or has not, received a particular MSDS.

Myth 3: "Hard copy MSDSs must be kept on the premises at all times in order to comply with OSHA's requirements."
As previously mentioned, many regulatory agencies, including local agencies such as fire departments, use MSDSs as a tool for identifying various hazardous materials that may be stored or transported by companies within their jurisdiction. Rarely do these agencies impose requirements beyond those of the OSHA Hazard Communication standard mandating that MSDSs be stored in a binder on site or even in a fireproof box outside the building.

However, OSHA requires only that MSDSs be readily available to employees without "barriers to access." Electronic access to this information is an acknowledged means of providing MSDS access. Keep in mind, however, that restricting employee access to the Internet would translate into restricted access to MSDSs (if the Internet is employed as the employee MSDS access tool) and would violate the requirements of the HazCom standard.

Myth 4: "Keeping the MSDS sent from the vendor on file is all a company needs to do for compliance."
Actually, while the standard does afford companies a great deal of flexibility in fulfilling the requirements of the standard in their workplaces, HCS compliance is a bit more complex than just filing away a sheet of paper that comes with a chemical delivery. All employees who may be affected by a particular hazardous material in their work areas must be trained on how to access and read the MSDS associated with that hazardous product.

MSDSs are only truly accessible--hence, Hazard Communication program-compliant--if an employee can match the correct MSDS to the product with which he or she is working. HCS also requires maintenance and availability of an inclusive hazardous product inventory, employee training, and container labeling.

A Useful Tool
The Internet can be a useful and robust tool for busy EH&S professionals. While properly acquiring and maintaining MSDSs is not a small job that can be solved with a few simple clicks of the mouse, Web-based solutions can be a valuable resource for managing MSDS needs.

This article appeared in the July 2006 issue of Occupational Health & Safety.

This article originally appeared in the July 2006 issue of Occupational Health & Safety.

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