Page 40 - OHS, November/December 2022

HAZARD COMMUNICATION
Everything You Need to Know about Safety Data Sheets
Safety Data Sheets are critical to informing employees of the hazards they face.ESG pr BY JADE BRAINARD
Over each of the past seven years, hazard communication (1910.1200) has been one of the top five most penalized OSHA standards.1 But concentrating your efforts on maintaining safety data sheets (SDSs) can help.
And that’s because a major component of any worksite’s hazard communications plan is its SDS.
But what is an SDS and why are these sheets integral to an employer’s hazard communications plan? This article will answer the questions you have about SDSs, how you can maintain them and why doing so protects your entire workforce.
An SDS is a 16-section source of information relating to a hazardous chemical in the workplace. OSHA standardized the number of sections in 2012 when it revised its Hazard Communication Standard to align with the UN’s global chemical labeling system.
SDSs must contain the information a worker needs to access in the event of an emergency—like the chemical name, its hazards and first aid procedures. More technical details, like handling and storage measures, should also be included on the SDSs.
When Do You Need a Safety Data Sheet?
OSHA uses the term “hazardous chemical” to identify which substances require SDSs on your site. But what exactly is a “hazardous chemical”?
OSHA defines it as “any chemical that poses either a physical hazard (such as flammability) or a health hazard (such as causing damage to the skin or eyes).”
So, what about commercial products, like Clorox or Lysol? OSHA provides guidance on these, as well (1910.1200(b)(6)(ix)).2 When employees use consumer products in the same manner and at the same frequency a consumer uses them, you don’t need an SDS for those products.
But this exemption doesn’t apply when employees work with hazardous chemicals in a manner greater than what a normal consumer would experience. In this case, employees have a right to know about the properties of those hazardous chemicals and have access to an SDS for those products.
As an example, let’s say you have Windex on your site. People use Windex to clean their homes. But if your team works with Windex frequently that it exceeds the amount an average con- sumer uses, you must provide an SDS for your site’s Windex. In other words, an SDS exemption is based on the workplace’s use of the product, not just the manufacturer’s intended use.
How Should You Maintain Safety Data Sheets?
It’s incumbent on employers to maintain the current version of the SDS for every hazardous chemical on their site. Even though you should request an SDS every time you purchase a hazardous chemical from a supplier or manufacturer, you may at some point need to update or create them yourself. There are a few reasons
compliant (e.g., they send an MSDS, not an SDS).
■ The supplier or manufacturer has changed its formula since
you last purchased the product.
New hazard information for a chemical on your worksite comes out.
Keeping your SDSs updated might sound tedious, but it keeps your worksite OSHA-compliant and, more importantly, it keeps your workers safe.
Let’s say one of your employees is exposed to Clorox Bleach. Your team leaps into action and consults the bleach’s SDS—but it’s six years old. For all you know, Clorox could have changed its formula in the time since. Because your team is working from older information, the affected employee might not receive the care they need. And that can be very dangerous, both for your employee and any first responders.
Maintaining your SDSs takes more than updating the format- ting and information, though. Here are two additional steps that go into maintaining your SDSs and keeping your worksite safe.
Designating an SDS Manager. Keeping track of new OSHA guidelines and changing product formulas takes a lot of work. That’s why you should assign these tasks to an SDS Manager. Your SDS Manager is the person responsible for obtaining and updat- ing your SDSs, which means the role generally isn’t a fit for an en- try-level employee. After all, this position requires a keen aware- ness of your worksite and familiarity with OSHA guidelines.
If you have a larger hazard communications program, you might decide to delegate the SDS management tasks to your program manager instead. A hazard communications program manager often oversees and executes the requirements of your program (which includes SDS management tasks).
Training your employees. OSHA’s Hazard Communication standard (29 CFR 1910.1200(a)) details the chemical hazard in- formation that employers must offer to employees.3 Specifically, OSHA notes that employers must “train employees on the haz- ardous chemicals in their work area before initial assignment and when new hazards are introduced. It’s critical that workers under- stand they are exposed to hazardous chemicals, know how to read labels and SDSs, have a general understanding of the information provided, and know how to access related tools.”
Put differently, training is an ongoing process. While offering it certainly achieves compliance, the more important result is a well-informed workforce that can easily spot hazards at your site.
Here are several elements your training should cover:
■ How to comprehend the information in SDSs and access them quickly.
■ Which measures employees should take to protect themselves, such as wearing the correct *PPE and understanding emergency procedures.
■ How to understand the labels received on shipping containers and that supplier’s or manufacturer’s labeling system.
Just as important as the content of your training program is how you administer it. For instance, think of how your team
why:
The supplier or manufacturer sends you an SDS that isn’t
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