Page 55 - Occupational Health & Safety, July 2017

The old adage of “document, document, and document” comes into play, because if it’s not documented, it didn’t happen. If an organization has employees who are poten- tially exposed to hazardous chemicals and there is no written program, but the provi- sions of labeling, SDSs and training are met, it would not be cited under 1910.1200(e) (1)—it would be viewed as a de minimis violation. However, if the converse is true, and it has a written program but has not applied one or more required elements, it would be cited under the specific section of the deficiency such as labeling, SDS, and/ or training.
2. Employee training requirements including chemical-specific information must always be available through SDSs:
CSHOs will evaluate the effectiveness of your organization’s hazard communi- cation training by reviewing the program materials and interviewing employees and management. The employees interviewed are not expected to recite verbatim all the information covered in the training. How- ever, they should be aware of the hazards to which they are exposed, understand how to use information on the SDSs, and know and follow job safety practices and protec- tive measures. Conducting random obser- vations and employee interviews to verify hazard communication training retention is a best practice.
3. Maintaining SDSs:
■ Employers do not need to maintain SDSs for non-hazardous chemicals.
■ The method (i.e., paper or electron- ic) of maintaining SDSs is left up to the em- ployer as long as the employees have imme- diate access to the SDS in their work area.
■ Older versions of SDSs or Material Safety Data Sheets (MSDSs) may still need to be maintained as an employee exposure record (29 CFR 1910.1020).
■ An Internet search is not considered an acceptable method to obtain an SDS.
■ Employees must have uninhibited access to SDSs on all shifts. The SDSs can- not be locked in file cabinets or offices or in a location where employees are required to ask for them.
It’s a good practice to conduct periodic verification of chemical inventory by ran- domly reviewing the master inventory list to see whether it matches with the label and SDS identifiers. A CSHO will review a
representative sample of chemicals on the shop floor to verify whether the chemi- cal matches the information found on the master list, SDSs, and labels.
Another pain point associated with maintaining SDSs is samples. A best prac- tice to follow is to have documented poli- cies and procedures, along with training of supply chain employees and supervisors to not accept samples without first receiving the appropriate SDS and recording the re- ceipt of the sample. This will help eliminate the undocumented small containers that everybody seems to find on the back bot- tom shelf of storage cabinets.
4. Developing SDSs:
It is the responsibility of the chemical manufacturer and importer to develop or obtain an SDS for each hazardous chemical they manufacture or import. The informa- tion provided on the SDS must conform to the required 16-section format, and the SDS must be sent downstream with the next shipment of the chemical or upon re- quest. Additionally:
■ Chemical manufacturers must up- date their SDS within three months of becoming aware of significant new infor- mation.
■ SDS requirements apply to no- charge samples provided by chemical man- ufacturers and importers.
■ The SDS must be provided in Eng- lish but can be translated into other lan- guages to facilitate training and improve retention by workers for which English is a second language.
During the inspection process, a CSHO will review samples of SDSs to determine whether they meet the standard. A CSHO also may need to determine whether a manufacturer or importer exercised “rea- sonable diligence and made good faith ef- forts” to obtain updated chemical hazard information. Again, you will need to pro- duce your documentation trail regarding the process to obtain necessary SDSs with upstream suppliers. They will look for at- tempts by the manufacturer to find hazard information from alternative sources or ef- forts to classify the data themselves. Also, a CSHO will take steps to verify the SDS transmission program is being followed to downstream recipients.
5. Employee SDS Training Details:
A hazard communication SDS training
program should include:
■ An overview and explanation of the
16-section SDS format
■ Information on where SDSs are lo-
cated and how to access them
■ Information on who to talk to
should there be questions about the SDS
■ Differences between MSDSs and
SDSs
When CSHOs conduct employee in-
terviews, they will focus on specific issues, such as where to locate the SDS and wheth- er or not employees have the necessary computer skills to access SDSs if they are in an electronic format.
Conclusion
OSHA will continue to evaluate whether to align the HCS with the United Nation’s Globally Harmonized System of Classifica- tion and Labeling of Chemicals (GHS). The United Nations updates the GHS on a bi- annual frequency and currently is on GHS Revision 7, 2017. This implies we could see additional changes down the road from OSHA, since it currently enforces GHS Re- vision 3, 2009.
SDSs are the backbone of every em- ployer’s hazard communication program. Ensuring your organization is compliant and all employees have access to the most current hazard information in the event of an accidental exposure or uncontrolled re- lease is crucial.
Familiarizing yourself with the infor- mation contained in OSHA’s compliance directive regarding the HCS is the best place to start your compliance self-assessment. By conducting periodic evaluations of onsite chemical inventories to ensure cur- rent SDSs are maintained and developing training for internal partners who request, purchase, or use hazardous chemicals, you can ensure your organization won’t become complacent in fulfilling its obligations un- der OSHA’s HCS.
John M. Eliszewski, MS, CSP, HACCP, QSSP, is a technical safety specialist at Grainger, a leader in safety services and so- lutions, offering technical support and train- ing to help customers comply with workplace safety regulations and safeguard facilities. For more information on creating a safer working environment, visit http://safety. grainger.com.
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