OSHA requires employers to maintain current Safety Data Sheets (SDS) on all chemicals used in the workplace, train employees on their use and make SDS readily available in the work area.
Centralized management of this effort is the key to efficiency, effectiveness and compliance. This starts with how containers of chemicals are received and distributed throughout your facility.
If you don’t have an SDS system, follow these steps
Determine the chemicals you use. There are several ways to determine what chemicals you have at your location. Using all of the following methods will provided the best coverage to prevent missing something.
1. Make a list of all suppliers that provide material covered by the OSHA standard... Don’t forget that items such as welding rods and bulk processing materials must be included.
2. Get a list from all suppliers of any chemicals they have sent you in the last three years
3. Conduct a thorough workplace survey. Have supervisors inventory all areas. Provide them with a form to record all chemicals found, the storage location, amount and end use.
4. Index all existing SDS by department
5. Send a letter to all suppliers requesting current SDS for all products they provide your company. Keep a checklist to ensure they are received.
6. Compare your SDS index with the list of chemicals from step 2. and 3.
7. Resolve any discrepancies and provide departments with updated SDS copies. Each SDS book location should have a table of contents that lists each chemical SDS that is required to be in that book. Keep a master index of each book and a master SDS in a central file that is controlled by one manager.
Assign your shipping manager as the key point for SDS management. This includes:
· Ensuring current SDS are in the Master book or computer files
· Updating all user department files
· Requesting new SDS from vendors and suppliers every year for all active products
· Manage and maintaining the chemical labeling system
· Notifying the Safety Department when new or modified SDS are added.
· Not releasing new products without permission from Safety Department
· Ensuring all containers are properly labeled before distribution.
· Determine chemical safety training requirements for all existing and new products
· Monitor chemical labeling program
· Monitor storage locations
· Verify safe usage procedures
· Making PPE determinations
· Periodically audit department SDS files to ensure they are up-to-date
· Ensure proper storage, labeling, dispensing and use
· Train employees on hazards and procedures
· Ensure SDS are readily available
· Ensure labels are legible
· Provide proper transfer and dispensing containers
· Segregate incompatible chemicals
· Control issue and return of unused chemicals
· Conduct weekly chemical safety checks
Once you have an complete paper SDS program established, you can now move to an electronic storage system with a high degree of confidence that all material will be covered. The system should provide a means to easily find and sort SDS by Product Name, Department and usage. OSHA requires that a backup method be available in the event of power outages or electronic equipment failure. Currently there are no chemical SDS databases that have all chemicals from all suppliers. You cannot rely on ‘generic" SDS since OSHA requires you to maintain the SDS provided for the specific product from the specific supplier.
Many current commercially developed databases allow for scanning paper copies into the database. This saves time in that data need not be re-typed into a standard format and you maintain the exact SDS provided by the supplier. The scanned files are then made available through the database program’s index system.
Scanned copies will not provide a searchable database unless you can also enter basic information about each file as it is added. As a minimum you will want a program the allows you to enter the name of departments that uses the specific SDS, product name, supplier and current SDS date.
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