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FAQ - Regulatory Processes - 2016
FAQ - Regulatory Processes - 2016

 

 

The question is, was the process of maintaining MDS sheets revised such that programs no longer have to keep sheets on EVERY substance used within the program (or just known hazards) and are physical hard copies required?

 

The OSAP website contains some OSHA and Hazard Communication related information which can be accessed at these links:

OSHA
http://www.osap.org/?page=GuideOSHA  1

OSHA Hazard Communication Standard Update
https://osap.site-ym.com/?page=OSHAHazCom   2

Ask OSAP can provide you with some general information on this topic.

The US Department of Labor – Occupational Safety and Health Administration (OSHA) maintains a Hazard Communication webpage which can be accessed at this link:
https://www.osha.gov/dsg/hazcom/index.html  3

OSHA’s Hazard Guidance Documents webpage can be accessed at:
https://www.osha.gov/dsg/hazcom/guidance.html  4

The OSHA Fact Sheet Steps to an Effective Hazard Communication Program for Employers That Use Hazardous Chemicals can be accessed at:   https://www.osha.gov/Publications/OSHA3696.pdf  5

 This document states in part:

Step 4. Maintain Safety Data Sheets (SDSs)
• Maintain safety data sheets for each hazardous chemical in the workplace.
• Ensure that safety data sheets are readily accessible to employees.
Safety data sheets are the source of detailed information on a particular hazardous chemical. Employers must maintain copies of SDSs for all hazardous chemicals present in their workplaces. If you do not receive an SDS from your supplier automatically, you must request one. You also must ensure that SDSs are readily accessible to workers when they are in their work areas during their work shifts.

This accessibility may be accomplished in many different ways. You must decide what is appropriate for your particular workplace. Some employers keep the SDSs in a binder in a central location (e.g., outside of the safety office, in the pick-up truck on a construction site). Others, particularly in workplaces with large numbers of chemicals, provide access electronically. However, if SDSs are supplied electronically, there must be an adequate back-up system in place in the event of a power outage, equipment failure, or other emergency involving the primary electronic system. In addition, the employer must ensure that workers are trained on how to use the system to access SDSs and are able to obtain hard copies of the SDSs. In the event of a medical emergency, hard copy SDSs must be immediately available to medical personnel.  3

Additionally, OSHA provides a publication entitled Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals which can be accessed at:  https://www.osha.gov/Publications/OSHA3695.pdf  6

This document includes a sample written Hazard Communication Program in Appendix A. 6

This document states in part:

In addition, the written program must include the following items:

Paragraph (e)(1): A list of the hazardous chemicals known to be present in the workplace. The list may be kept using any product identifier from the SDS. Thus, the list may be kept by product name, common name, or chemical name. The important aspect of this requirement is that the term used on the list must also be available on both the SDS and the label so that these documents can be cross-referenced. The list can be compiled in whatever way the employer finds most useful and applicable to the workplace. A list of all hazardous chemicals in the entire workplace may be most suitable for very small facilities, where there are few work areas and all workers are potentially exposed to essentially the same products. For larger workplaces, it may be more convenient to compile lists of hazardous chemicals by work area and have them assembled together as the overall list for the workplace.

The list is an inventory of chemicals for which the employer must ensure that there is an SDS available. Compiling the list also helps employers keep track of the chemicals present, and to identify chemicals that are no longer being used, and thus could be removed from the workplace. Removing such chemicals may also reduce potential adverse effects that could occur in the workplace.

The best way to prepare a comprehensive list may be to survey the workplace. Purchasing records may also help and employers should establish procedures to ensure that purchasing procedures result in receiving SDSs before a material is used in the workplace. Prior to purchasing chemicals, review the hazards of the chemicals and evaluate if less hazardous chemicals can be used instead.  6

Pages 20-24 provides additional information on SDS compliance for employers. It states in part:

Employers must have an SDS for each hazardous chemical which they use. Employers may rely on the information received from their suppliers unless they know the information is incorrect. If you do not receive an SDS automatically, you must request one as soon as possible. If you receive an SDS that is obviously inadequate, with, for example, blank spaces, you must request an appropriately completed one. If your request for an SDS or for a corrected SDS does not produce the information needed, you should contact your local OSHA area office for assistance in obtaining the SDS. Employers must maintain the current version of the SDS; if a new SDS is received with a shipment, they must maintain and make available the new SDS.

The SDSs must be in English. Many larger manufacturers also produce SDSs in other languages. If you have workers who speak language(s) other than English, you may be able to obtain SDSs in those languages to ensure effective hazard communication.

Employers must maintain copies of SDSs in their workplaces, and must ensure that SDSs are readily accessible to workers when they are in their work areas during their work shifts. This accessibility may be accomplished in many different ways. You must decide what is appropriate for your particular workplace. Some employers keep the SDSs in a binder in a central location (e.g., in a pick-up truck on a construction site). Others, particularly in workplaces with large numbers of chemicals, provide access electronically. However, if access to SDSs is provided electronically, there must be an adequate back-up system in place in the event of a power outage, equipment failure, or other emergency involving the primary electronic system. As long as workers can get the information when they need it, any approach may be used. When workers must travel between workplaces during a work shift, SDSs may be kept at the primary workplace facility. No matter what system is used, employers must ensure that workers and medical personnel can immediately obtain the required information in an emergency.

In order to ensure that you have a current SDS for each chemical in the plant as required, and that worker access is provided, OSHA’s CSHOs will be looking for the following items in your program:

1. Designation of person(s) responsible for obtaining and maintaining the SDSs;

2. How such sheets are maintained in the workplace (e.g., in notebooks in the work area(s) or electronically), and how workers obtain access to them when they are in their work area during the work shift;

3. Procedures to follow when the SDS is not received at the time of the first shipment;

4. An SDS for each hazardous chemical in the workplace, and training of workers that includes review of SDS format and use  6

OSHA also provides an OSHA Brief pertaining to the Hazard Communication Standard and Safety Data Sheets which can be accessed at:   https://www.osha.gov/Publications/OSHA3514.html  7

Sections 1 through 8 of the SDS contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures (e.g., fire fighting).  7

In summary, a comprehensive list of hazardous chemicals used in the workplace can be compiled through a workplace survey. The SDS will list the name of the specific hazardous chemical(s) present in the product. There are various requirements regarding compliance with the Hazard Communication Standard. You will need to develop a system that maintains a current list of hazardous chemicals used in the workplace, as well as the SDS’s for these products. Ask OSAP can provide you with information pertaining to what the requirements are, however Ask OSAP is not in the position to advise you as to the best methods to achieve compliance in your workplace. That is something that you will have to decide upon.

It is recommended that you direct any further questions on this matter to your area OSHA office. Please note that there may be varying requirements in those states with State OSHA Programs. Further information about State OSHA Programs can be accessed at https://www.osha.gov/dcsp/osp/index.html  .8

Resources

1)    Organization for Safety, Asepsis and Prevention.  OSHA.  http://www.osap.org/?page=GuideOSHA  Accessed on November 2, 2016.

2)     US Organization for Safety, Asepsis and Prevention. OSHA Hazard Communication Standard Update. https://osap.site-ym.com/?page=OSHAHazCom  Accessed on November 2, 2016.

3)     Department of Labor – Occupational Safety & Health Administration. Hazard Communication. https://www.osha.gov/dsg/hazcom/index.html  Accessed on November 2, 2016.

4)     US Department of Labor – Occupational Safety & Health Administration. Hazcom Guidance Documents. https://www.osha.gov/dsg/hazcom/guidance.html  Accessed on November 2, 2016.

5)     US Department of Labor – Occupational Safety & Health Administration. OSHA Fact Sheet -  Steps to an Effective Hazard Communication Program for Employers That Use Hazardous Chemicals  https://www.osha.gov/Publications/OSHA3696.pdf  Accessed on November 2, 2016.

6)     US Department of Labor – Occupational Safety & Health Administration. Hazard Communication: Small Entity Compliance Guide for Employers That Use Hazardous Chemicals. https://www.osha.gov/Publications/OSHA3695.pdf  Accessed on November 2, 2016.

7)     US Department of Labor – Occupational Safety & Health Administration. OSHA Brief – Hazard Communication Standard: Safety Data Sheets. https://www.osha.gov/Publications/OSHA3514.html  Accessed on November 2, 2016.

8)     US Department of Labor – Occupational Safety & Health Administration. Frequently Asked Questions about State Occupational Safety and Health Plans. https://www.osha.gov/dcsp/osp/index.html   Accessed on November 2, 2016.  

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