MSDS Management
Material Safety Data Sheets (MSDS) are required documents under OSHA Hazard Communication standards (29CFR1910.1200). Manufacturers are required to produce MSDS for any chemicals having components with physical or health hazards. While there are requirements for must be contained on MSDS, much of the information is boiler plate/legal disclaimer except for the physical data. The MSDS requirement as prescribed in HazCom can require significant effort for limited value.
OSHA requires MSDS be available, without barriers, for all employees on every work shift. The theory is MSDS will contain specific material data that employees can reference and have full knowledge of material hazards, treatment for exposures, protective measures etc. The reality is MSDS are really only used to retrieve technical information. Specific information regarding hazards, treatment etc. are often obtained from other sources based on the components listed on the MSDS. Ironically the technical data most often used, hazardous components, are reported as a range of weight percent rather than a specific value. To obtain specific content component weight percent, a Certified Product Data Sheet (CPDS) is needed. Given the limited intrinsic value of MSDS, what can be done to maximize the value of maintaining MSDS as required?
When evaluating how to maintain MSDS information and maximize value, ensuring compliance is where to start. Let’s face it, we maintain MSDS because it is required so we must meet those requirements first. To maximize the value delivered by meeting the MSDS management requirements, review your environmental regulatory requirements and index your MSDS by specific hazards and components. Too often the safety and environmental management systems are independent of each other and you end up a separate data file of chemical information for environmental reporting. Using one system for both sets of requirements can increase value by reducing effort required for data management. Having your MSDS indexed by hazard and component can be very helpful when new regulations are proposed or specific safety concerns arise.
Archiving obsolete data and limiting MSDS in the active system to only what is currently used can also significantly increase value. Without an archive process, the number of documents to search can become quite large quickly and employees can have difficulty determining the correct MSDS for a product. MSDS are considered medical records and must be maintained for 30 years past employment, so an archive process is required, but often the process used is time intensive and neglected because of conflicting priorities or time constraints of the person maintaining the system. The most effective archive processes are usually tied directly to material procurement so changes are initiated at the source.
MSDS requirements and practical application can create challenges for safety managers. Focusing on how and what material information is actually used can create synergies and maximize the value your chemical management system provides.
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