Is managing Material Safety Data Sheets electronically OSHA-compliant?
Answered by Glenn Trout, president, MSDSOnline, Chicago.
In short, the answer is "yes" as long as a company meets the following three criteria:
- It has a backup system in place in case of a foreseeable emergency; that being any situation that renders the electronic system inaccessible or inoperable (service interruptions, power outages, etc.).
- It ensures the electronic system, same as a traditional paper-based system, is integrated into the overall hazard communication plan. Employees must be made aware of the MSDS management system that is in place, and must be trained on how to access and use the system.
- It ensures employees have access to hard copies if requested. It's a common misconception that paper MSDS management systems – typically three-ring binders – are the only compliant MSDS management solution. While OSHA's hazard communication standard (1910.1200) requires companies to produce hard copies of MSDSs upon request, it does not require companies to use a paper-management solution or even have pre-printed copies of MSDSs on hand.
According to the hazard communication standard, OSHA has no objections to electronic MSDS management systems. In fact, it has permitted the use of electronic management solutions since 1989. Section 1910.1200(g)(8) of the regulation states that companies can use whatever management options work for them "as long as employees can get the information when they need it."
Depending on the work environment, companies should consider backing up MSDS libraries by burning them onto CDs or printing master paper sets at least once a year. This way, in the event of an emergency, MSDSs are still readily available upon request. This is much easier to accomplish when using an electronic system to manage the data.
Another viable backup alternative is an on-demand fax system. Most electronic MSDS management providers today offer fax-back services. These are great as a backup solution or for making MSDSs available to employees in the field or in places without Internet connectivity. However, a fax-back service is not recommended as a stand-alone solution. On its own accord, a fax system does not meet the OSHA compliance requirements in many workplace settings.
It is estimated that more than 7 million facilities in the United States regularly handle chemicals. In addition, OSHA reports that each year, more than 100 million American workers are exposed to hazardous chemicals in the workplace. The cost of non-compliance is no longer limited to only fines and penalties. Failure to comply can lead to increased employee days away from work, higher workers' compensation claims, operational slowdowns, and potential legal and litigation fees, as well as a negative impact on a company's image with customers.
Unfortunately, manual paper-based systems are inefficient and labor intensive. Managing a compliant 2,000-document MSDS library can cost as much as $50,000 (in hard and soft costs) annually. Therefore, if a business has hundreds or thousands of MSDSs, the savings (in time, money and paper) of adopting an electronic management solution makes good financial sense.