Apogee EHS Group

Material Safety Data Sheets (MSDS, will be referred to Safety Data Sheets, SDS, if Global Harmonized System is adopted) are a required to be maintained under the Hazard Communication standard (CFR29.1910.1200). While the intention of maintaining documented specific chemical hazard information is logical (essentially why MSDS are required), in practice the maintenance of MSDS is little more than a paperwork filing exercise.  MSDS must be available for employees exposed to chemical hazards for the purpose of accessing additional information, however the only person that usually refers to an MSDS for information is someone responsible for safety management.  This practical reality and the intent of regulatory requirements for communication of chemical hazard information brings into question if employees must be able to read and understand a MSDS as a requirement.

To answer the question of how adept employees must be at reading a MSDS, you first need to evaluate the actual information included on MSDS.  The majority of a MSDS is boiler plate legal text.  Unfortunately, much of the hazard and precautionary information on MSDS is boiler plate.  For example, “A system of local and/or general exhaust is recommended to keep employee exposures as low as possible” or “Dispose of container and unused contents in accordance with federal, state and local requirements”. Manufacturers are reluctant to include specific safety recommendations and are also reluctant to exclude generic warnings even for very innocuous materials.  Usually, the only material specific information on a MSDS is physical characteristics (such as specific gravity and boiling point) and testing data such as toxicology testing, if such testing has been completed.  Even specific material component information can be misleading.  Ranges are usually given for material composition, and since most chemicals have several different names, the names used for a material component can even be misleading and the CAS number used.  I have seen the name Yellow Chromate used instead of Lead Chromate on paint MSDS because the manufacturer is concerned that as soon as the word Lead is seen, the paint will not be used (which it should not be used).  Basically, without some general chemistry knowledge MSDS information can be misleading or unusable.

Most plant employees will not have general chemistry knowledge to help them use MSDS information effectively.  Training on the specific details available in a MSDS will essentially be a waste of time and will usually only undermine your safety program by being “Another boring safety presentation about information that does not affect us on the floor.”  This can serve as another example to employees that safety is about rules and not about what they actually do every day.  The key to effective safety management is employee engagement in the safety process.  Getting to involved in technical details (what the Safety Manager should worry about) without bringing it into day to day work decisions and processes can demonstrate to employees that safety is an office process, not a work process that extends to everything we do.  To achieve an injury-free workplace, the safety process must be brought to the floor level and extend into every task performed.  Therefore, training on the content of MSDS should be limited to information employees can find useful or interesting, and many of the details left in the hands of the Safety Manager.

Whenever effective safety management systems are brought up on discussion boards on networking sites such as LinkedIn and Facebook, terms such as employee accountability, commitment from management and employee engagement are often the crux of the discussion.  These terms are usually discussed very matter-of-fact as if a singular definition exists and can be applied to every organization.  My experience has shown me that establishing and cultivating these three important concepts; employee accountability, commitment from management and employee engagement; is different in each organization due to cultural factors, personal beliefs and business management “styles”.

Employee accountability is the general concept that employees have accountability for the choices or decisions they make.  How a business is managed and the current culture “on-the-floor” dictate what employee accountability means within an organization.  A “work team” operational environment will have different accountability traits then a top-down organization where clear expectations and direction are issued.  These factors also dictate how employee accountability needs to be cultured to establish the necessary commitment for an effective safety management system.

The keys to establishing employee accountability, in any organization, are an expectation to work safe and clear understanding by employees the difference between working safe and being at-risk for injury.  How and what this will exactly mean depends on the factors mentioned above, establishing what is safe and an expectation to work safe will allow employees to be accountable for themselves and accept consequences when not meeting the expectation to work safe.

Management commitment can best be described as the expectation from the highest level of management that nobody should ever be injured on the job, and “we” need to do whatever is reasonably necessary.   The fact “should” and “reasonably” are in the description demonstrates the variation in management commitment between organizations….and also leads to the discussions.  Too often, people expect an organization to take a management stance that is not reasonable for the current state of the organization and criticize the “lack of management commitment”.  You need to work within the current state of an organization to cultivate a future state where less and less is considered un-reasonable.

Employee engagement in the safety process can take many forms; from safety committee membership to basic hazard reporting or safety suggestion submission.  Essential to establishing employee engagement is meeting employees at their ability and level of desire.  The goal is to engage as many employees as possible, and to “delegate” as much down as capabilities allow.  You need to engage as close to 100% as possible, but you also need to make sure you engage employees at a level that matches their desire and ability.  Those that have leadership ability and want to make a difference must engaged differently than those just wanting to come to work each day be left alone.

An effective safety management system requires employee accountability, management commitment and employee engagement, but these concepts are not simple absolutes.  They are fluid definitions that advance with an organization.  This is brief, and does not due the topic justice, but I hope this can begin the discussion so this concept can be explored.