Maintain Safety Data Sheets (SDSs)
Paragraph (g) of HazCom 2012 states that employers must have an SDS in the workplace for each hazardous chemical they use.2,4 An important aspect of the HazCom program is to ensure that someone (e.g., the HazCom Coordinator or a designee) is responsible for obtaining and maintaining the SDSs for every hazardous chemical in the workplace. If an SDS is missing, one must be requested from the distributor. To shows good faith effort to obtain an SDS, it is prudent to document the request (e.g., keep copy of the letter or e-mail; make a note regarding telephone contact). If the request for an SDS does not produce the information needed, the local OSHA area office should be contacted for assistance. A hazardous chemical for which there is no SDS on file should not be used until the SDS is obtained.
The SDSs have 16 internationally agreed upon components or sections that contain information for many different audiences (e.g., employers, workers, safety and health professionals, emergency responders, government agencies, and consumers). Consequently, the sections have been organized so that the information of most use to exposed workers, emergency responders, and others who do not need extensive technical detail is in the beginning of the SDS (Table 5).
For example, a description of a chemical’s health effects appears in Section 2 (Hazard identification), but the toxicological data upon which the determination of these effects is based appears in Section 11 (Toxicological information). All of the sections are available to any reader, but there is a difference between what is necessary for a broader audience and what might be needed by others designing protective measures or providing medical services.
The information in some of the sections is non-mandatory because they address information that involves the requirements of other government bodies, and thus they are not under OSHA’s jurisdiction. Even though these sections are not considered mandatory by OSHA, the sections are still required. They provide useful information related to ecological, disposal, and transportation-specific issues under the regulatory control of other agencies.
Employers must not only maintain copies of SDSs, they must also ensure that the SDSs are readily accessible to workers during their work shifts. Some employers keep the SDSs in a binder in a central location, others 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.
Familiarity with the information in each section of an SDS will enable both employers and employees to quickly access this information in case of an emergency. A section-by-section description of the information required for each part of the SDS is available in Appendix D of HazCom 2012.2 OSHA also developed a QuickCard™ on SDSs (OSHA 3493) available on the OSHA Hazard Communication website.7 The SDSs must be in English, although the employer may maintain copies in other languages.
Box D. Safety Data Sheets.4
Section D: Safety Data Sheets
(Name of responsible person and/or position) is responsible for establishing and monitoring the company’s SDS program. The procedure below will be followed when an SDS is not received at the time of initial shipment:
Describe procedure to be followed here
Copies of SDSs for all hazardous chemicals to which workers are exposed or are potentially exposed will be kept in (identify location). Workers can access SDSs by (insert procedure for access).
Note: If alternatives to paper copies of SDSs are used, describe the format used and how workers can access the SDSs.
SDSs will be readily available to all workers in each work area during each work shift. If an SDS is not available, contact (name of responsible person and/or position).
When a revised SDS is received, the following procedure will be followed to replace old SDS:
Describe procedure here
(Name of responsible person and/or position) is responsible for reviewing the SDSs received for safety and health implications, and initiating any needed changes in workplace practices.
Informing Other Employers About Hazardous Chemicals in the Workplace
Where there is more than one employer operating on a site (e.g., several dental practices within the same physical setting), employees may be exposed to the chemicals used by each employer. For example, in a physical space with five dentists only one may use nitrous oxide, but because of the facility’s open design, all employees may be exposed to nitrous oxide that escapes containment during use.
In these cases, paragraph (e)(2) requires that the written HazCom program be coordinated.2,4 Each employer must address (1) how on-site access to SDSs will be provided to the other employer(s), (2) how such employers will be informed of needed precautionary measures, and (3) how such employers will be informed of the on-site labeling system if it is different from the labels specified for shipped containers under the standard.
Box E. Informing Other Employers About Hazardous Chemicals.4
Section E: Informing other employers about hazardous chemicals
It is the responsibility of (name of responsible person and/or position) to provide other employers with information about hazardous chemicals that their workers may be exposed to in our shared setting.
It is the responsibility of (name of responsible person and/or position) to obtain information about hazardous chemicals used by other employers to which our workers may be exposed to.
Other employers will be provided with SDSs for hazardous chemicals used by this practice in the following manner:
Describe company policy here
In addition to providing a copy of an SDS to other employers, other employers will be informed of necessary precautionary measures to protect workers exposed to chemicals used in our workplace.
Also, other employers will be informed of the hazard labels used. If alternative workplace labeling systems are used, the other employers will be provided with information to understand the labels used for hazardous chemicals to which their workers may have exposure.