Page 50 - Occupational Health & Safety, July 2017

GHS/SDS TRAINING
Best Practices for Safety Data Sheets
Don’t let complacency permeate your hazard communication program.
BY JOHN M. ELISZEWSKI
The one-year anniversary of the final phase-in date for the Occupational Safety and Health Administration’s (OSHA’s) revised Hazard Communication standard (HCS), Title 29 Code of Federal Regulations (CFR) 1910.1200, has come and gone. By June 1, 2016, employers were re- quired to update alternative workplace labeling and hazard communication programs as necessary and provide additional employee training for newly iden- tified physical or health hazards.
A key component of a company’s written haz- ard communication program are Safety Data Sheets (SDSs), which are written or printed materials around hazardous chemicals prepared in accordance with the requirements in paragraph (g) of the HCS.
The HCS habitually finds itself on OSHA’s Top Ten Most Frequently Cited Violations, and it made the list again in Fiscal Year 2016. Of the top five sections cited under the HCS, SDSs were referenced—either directly or indirectly—in all five, which validates the crucial role SDSs play. The top five cited sections during FY 2016 were:
1. 29 CFR1910.1200 (e)(1): Execution of the writ- ten hazard communication program which describes in detail the employer’s labeling, SDSs, and training components.
2. 29 CFR1910.1200 (h)(1): Employee training re- quirements, including chemical-specific information that must always be available through labels and SDSs.
3. 29 CFR1910.1200 (g)(8): Maintaining SDSs.
4. 29 CFR1910.1200 (g)(1): Developing SDSs.
5. 29 CFR1910.1200 (h)(3) (iv): Details in the
hazard communication employee training pro- gram, including an explanation of labels and the SDSs, including how employees can obtain and use the information.
With a flurry of OSHA regulatory activity at the end of President Obama’s administration that con- tinued into President Trump’s first months in office, it’s easy to have lost sight of the state of your hazard communication program. That said, complacency has been the ruin of many good hazard communication programs, and some re-focused attention on your or- ganization’s SDSs may help you stay compliant.
Employers are required to have an SDS available for each hazardous chemical they have on site, and the information contained on them is the basis for training their employees on the hazards of the chemi-
cals to which they are exposed, according to 29 CFR 1910.1200 (h)(3)(iv).
The SDS plays a unique role in assisting em- ployers in situations where the chemicals at their facilities have no OSHA permissible exposure limit (PEL). Currently, there are about 500 chemicals that have an established PEL, and the SDS affords the safety decision maker facts to make informed deci- sions on their potential hazards while conducting a hazard assessment for new chemicals introduced into the workplace.
Hazard Communication Compliance Directive
The best resource for guidance on how an OSHA Compliance Safety and Health Officer (CSHO) will interpret SDS scenarios is OSHA’s compliance direc- tive number CPL 02-02-079, entitled “Inspection Procedures for the Hazard Communication Stan- dard (HCS 2012).” There, you will find detailed in- structions designed to provide uniform enforcement of OSHA’s HCS policies and procedures by federal OSHA CSHOs.
There isn’t a better way to evaluate a safety and health program for compliance than knowing, in advance, what inspectors will be looking for if—and when—they arrive at a facility. Be aware, this is a fed- eral OSHA document, and state plans are expected to have standards in place that are, at a minimum, as stringent as the federal requirements.
Here are some industry best practices to help keep your SDS library up to date and compliant based on the top five cited sections of the HCS:
1. Execution of the written hazard communication program, which describes the employer’s SDS compo- nents in detail. Written program SDS requirements are low-hanging fruit for CSHOs because of the com- plexity and ever-changing nature of organizations. Key SDS components that are sometimes overlooked in the written program include:
■ Not identifying employee(s) responsible for obtaining/maintaining the SDSs
■ Not describing how the SDSs are maintained
■ Not providing procedures to retrieve the SDSs electronically, identifying backup systems in the event of a power failure, or instructing employees how to obtain access to the SDSs
■ Not providing procedures in cases where the SDS is not received with the initial shipment of a chemical
■ Not providing procedures to follow if the SDS is missing information (blank spaces)
■ Not providing instructions on how to identify whether the SDS is the most current version
50 Occupational Health & Safety | JULY 2017
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