The SCHC OSHA Alliance hosted OSHA’s Lana Nieves and Sven Rundman of The Directorate of Enforcement Programs in a webcast to explain what importers and manufacturers need to do in developing a compliant safety data sheet. In this podcast, we focus on safety data sheets discussed in that webcast.
SCHC is The Society for Chemical Hazard Communication. The Hazard Communication Standard enforcement directive is OSHA’s program to align with GHS, the Globally Harmonized System.
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Dan Clark: New safety data sheet rules are in place from OSHA. Many people are thoroughly confused or frustrated with these SDS changes, initiated June 1st, 2015. Explaining part of this new Hazard Communication Standard, two OSHA experts answer 5 Safety Data Sheet questions next.
Hello, I’m Dan Clark of The Safety Brief, tackling health and safety hazards in today’s demanding industrial and construction worksites, a service of Creative Safety Supply.
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OSHA has a new Hazard Communication Standard as of June 1st, 2015, but many are stumped by the new rules regarding the safety data sheet.
OHSA hosted a webinar to answer HCS questions. To make it easy for you, I’ve isolated the answers on SDSs. OSHA Hazard Communication experts Lana Nieves and Sven Rundman took five questions on safety data sheets.
#1. The name Material Safety Data Sheet (MSDS) has been changed to just Safety Data Sheet. Do the old hard copy MSDS books have to be replaced with ones stating “SDS?”
Lana Nieves: Thank you. Employers must maintain the most recent version of an SDS or MSDS. We don’t really require what you call it, as long as it’s training and they can find it and locate it and they know what’s inside. That’s all we require.
Dan: #2. How do you handle the situation when a manufacturer has not issued the appropriate SDS?
Sven Rundman: Well, you know, on the employer’s part, that if they suspect there’s a newer version of a safety data sheet, they should be contacting the manufacturer to obtain the most recent version. If there’s a little bit of reluctance on the part of the manufacturer or employer to provide any new or appropriate SDS, if you believe there is one, the employer does have the right to file a complaint or call the OSHA area offices locally to see about getting some assistance on helping them obtain the SDS.
Dan: #3. Are hard copies of safety data sheets still required to be kept in chemical storage areas or are online versions acceptable?
Lana: The HCS doesn’t specify how the SDS or MSDS is maintained. It can be paper or electronic. However, it has to be accessible in the work area. If it’s electronic they shouldn’t have to look it up in Google or Yahoo. And backup procedures should be place, in case if it’s electronic, if the electricity goes down or they need to be trained on how to use the computer program, all that has to be addressed if they use an electronic version.
Dan: #4. Please give us the straight scoop about the employer’s responsibilities if a manufacturer is not updating their MSDSs to SDSs.
Sven: There may be a manufacturer or importer that have not received information to develop 2012 safety data sheets or labels. And, basically, the employer needs to maintain some sort of dialogue with their upstream suppliers determining when they’ll be in compliance so the downstream user / employer can be in compliance. So, basically, keep the communication lines open with those manufacturers or distributors.
Dan: #5. OSHA’s not enforcing the pictogram with the fish and tree on it. Will there be any calls made to an environmental agency?
Lana: OSHA does not enforce, because it’s outside OSHA’s jurisdiction. So, we don’t enforce it, then we can’t really call other agencies on something we don’t enforce. That’s in our non-mandatory sections of the SDS.
Dan: Alright, there we have important answers to a few safety data sheet questions. Thanks to OSHA HazCom experts Lana Nieves and Sven Rundman for the info.
That’s all for this episode, 5 Safety Data Sheet Questions For OSHA. Come back for more ways to stay safety compliant in today’s ever-changing landscape of safety requirements. I’m Dan Clark of The Safety Brief, a service of Creative Safety Supply. Save 10 percent off your entire order at creativesafetysupply.com with coupon code BIG10.
The OSHA Hazard Communication Safety Data Sheets QuickCard is here.
This podcast features highlights from the SCHC OSHA Alliance webcast Hazard Communication 2012 – Inspection Procedures for the Hazard Communication Standard: CPL 02-02-079. Hear and see the complete webcast here.
SDS illustrations by Thom Cheney © 2015 Creative Safety Supply; image of chemical inspection by US Navy/Edward Guttierrez; image of blue chemical tanks by USAID Vietnam; image of green chemical tanks by US Dept. Of Energy