A Safety Data Sheet (SDS) is a standardized document designed under the Globally Harmonized System (GHS) to communicate comprehensive hazard information about chemical products. Its primary purpose is to inform users about the risks, safe handling procedures, and emergency response actions associated with a substance. Electronic storage is permissible, but its use requires adherence to specific regulatory conditions to ensure workplace safety.
The Legal Basis for Electronic SDS Storage
The authority for utilizing electronic methods for Safety Data Sheet storage stems directly from the Occupational Safety and Health Administration (OSHA) regulations. The agency’s Hazard Communication Standard (HCS), specifically codified under 29 CFR 1910.1200(g)(8), allows for the use of non-paper formats. This provision permits methods like computers, microfiche, or fax machines to maintain the required chemical information.
Employers may choose these digital methods provided they ensure the information is readily accessible to employees during all work periods. The regulation places the burden of proof for accessibility and functionality squarely on the employer. The system must function flawlessly, demanding careful implementation and maintenance.
Mandatory Requirements for Immediate Accessibility
Compliance with electronic storage hinges on fulfilling the requirement for immediate and unrestricted access to Safety Data Sheets. An SDS must be available without delay, meaning an employee must be able to retrieve the document instantly when they need to understand a hazard or during an emergency. This requirement extends across all operational schedules, mandating that the system must be fully functional during every work shift, not just standard business hours.
The system’s reliability requires employers to proactively address potential points of failure. Equipment must be maintained and operational at all times to prevent interruptions. A failure of the electronic system, whether due to a server crash or a power outage, is not an acceptable excuse for lack of access to the required hazard data.
Employers must implement an adequate backup system to ensure continuity during system failures. This often takes the form of a secondary electronic system, such as a local server, or a physical hard-copy binder of the most commonly used Safety Data Sheets. The electronic system must be accessible to every employee in their work area without needing to request permission or travel to a distant location. The system cannot present physical or technical barriers, such as complex logins or lack of necessary hardware, that would impede timely retrieval.
Practical Options for Digital SDS Management
Companies have several technology choices for implementing compliant electronic Safety Data Sheet management systems.
Dedicated SDS Management Software
Dedicated SDS management software represents a professional solution, often offering features like automated indexing, advanced search functions, and version control updates from manufacturers. While these commercial systems require a subscription cost, they reduce the administrative burden of manual upkeep and ensure data integrity.
Cloud-Based Platforms
Cloud-based platforms provide similar functionality with the benefit of remote accessibility and off-site data redundancy. This structure is beneficial for organizations with multiple worksites or mobile teams requiring access across various locations. Reliance on an external internet connection, however, introduces a potential point of failure that must be mitigated with local backups or cached data access capabilities.
Internal Servers or Intranet
Utilizing internal company servers or an intranet system is often a more cost-effective approach, leveraging existing Information Technology infrastructure. This method gives the company full control over the data and security protocols. However, this option demands internal maintenance, including manually updating SDS documents and creating internal search capabilities to ensure quick retrieval.
Mitigating Risks and Ensuring System Reliability
Achieving regulatory compliance requires addressing the operational challenges inherent in relying on electronic systems. A primary strategy for failure prevention involves implementing uninterruptible power supplies (UPS) for all computers or servers hosting the SDS database. This equipment provides a temporary power source, allowing the system to remain accessible or shut down safely during short-term electrical failures.
Maintaining a limited physical backup further mitigates risk, often by keeping a binder of the Safety Data Sheets for the ten most hazardous or most frequently used chemicals near the work area. This measure provides immediate paper access when the electronic network is down. Access must also be ensured for employees who do not regularly use a computer, which can be accomplished through dedicated kiosks or company-provided mobile devices.
The system must facilitate access for external parties, specifically medical personnel and emergency responders, who might need chemical information immediately during an incident. The system design must account for rapid external access without complex security protocols that would slow down a time-sensitive response.
Training Employees on Electronic SDS Access
The Hazard Communication Standard requires that employee training covers the physical and health hazards of chemicals and the specific methods used to access the Safety Data Sheets. Training must ensure every employee knows the exact procedure for retrieving an SDS from the electronic system, including understanding the search interface, navigating the database, and identifying the correct version of the document.
Hands-on exercises are necessary to test an employee’s ability to quickly locate a specific Safety Data Sheet during a simulated emergency scenario. The training should be practical, ensuring the worker can efficiently use the hardware, whether a desktop computer, a mobile tablet, or a designated kiosk. Documenting this training verifies that the employer has fulfilled the obligation to make the information available and understandable to the workforce.
Maintaining Compliance Through Regular Audits
Maintaining continuous compliance requires a proactive approach centered on regular administrative and system audits of the electronic SDS library. System functionality checks must be performed routinely to ensure all hardware is operational and all electronic links are correctly directing users to the appropriate documents. This prevents access failures due to broken file paths or malfunctioning equipment.
A version control process is necessary to replace outdated material safety data sheets (MSDS) with the current Safety Data Sheet (SDS) format as new supplier information is received. When a new hazardous chemical is introduced, the corresponding SDS must be uploaded to the electronic system immediately and indexed correctly before the chemical is used.
Employers must also be mindful of regulatory requirements for record retention, which mandate that records of chemical exposure monitoring and employee medical records must be retained for specific periods. While the SDS itself does not have a federally mandated retention period after the chemical is no longer in use, the system managing the data needs to be audited to ensure it meets all associated recordkeeping obligations.