Safety Tidbit #20 - Ready Accessibility to the SDS

So we all know that the old Material Safety Data Sheets are now Safety Data Sheets and some believe that they are the same thing just they shortened the name.  However, that is not the subject of this week’s safety tidbit.  This week I would like to talk about the portion of the Hazard Communication standard that requires the employee has unobstructed access to the manufacturer’s information on the materials used in the workplace. 

According to 1910.1200(b)(4)(ii) - “Employers shall maintain copies of any safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals, shall obtain a safety data sheet as soon as possible for sealed containers of hazardous chemicals received without a safety data sheet if an employee requests the safety data sheet, and shall ensure that the safety data sheets are readily accessible during each work shift to employees when they are in their work area(s).”  Under paragraph 1910.1200(g)(1) – “Employers shall have a safety data sheet in the workplace for each hazardous chemical that they use.”  And still further in 1910.1200(g)(8) – “The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)”

            The confusion comes when folks remember that OSHA has a standard (1910.1020) that specifies access to employee exposure and medical records.  1910.1020 requires that “access is provided in a reasonable time, place, and manner.”  So let’s talk today about the term “readily accessible” and how HazCom’s paragraph 1200(g)(8) specifies no barriers to immediate employee access.  We need to look at OSHA’s letter of interpretation from 1999 where OSHA spells out what is meant by readily accessible. 

With the change to the content of SDSs and the prevalence of internet in the workplace, many employers are going to online services to maintain their SDS files.  These services are convenient and save having to have a paper copy in the workplace.  However, to meet the definition of readily available each worker must have untethered access to the online service.  Therefore, having to enter a supervisor’s office to use the community computer can be construed as a barrier.  Similarly, on a construction site, if the employee must ask a site foreman or supervisor for the SDS, which the supervisor then can look up on his or her smartphone.  Ultimately, If the employee must ask the supervisor for the chemical information then 1910.1200(g)(8) has not quite been met. 

Remember this part of the Hazard Communication standard is not about how quickly you can locate the right SDS.  It is about being able to request the SDS to start.