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For MSDS compliance, like many other tasks that involve information
management, the Internet is considered by some to be the “killer
app.” However, acquiring and maintaining MSDSs via the Internet is
no small job. Can your company actually use the Internet to better
manage its MSDS needs?
When used properly, the Internet can be a cost effective and
efficient tool for researching material safety data sheet (MSDS)
compliance requirements and managing the compliance process. It can
enable you to maintain MSDS compliance by helping you find the MSDSs
that you require and provide assistance in managing them.
There are many benefits to using the Web to research and manage
MSDSs, including universal accessibility, easy documentation,
simplified data storage and low cost. The Internet offers an
excellent starting point to facilitate MSDS management and maintain
compliance.
The following are a few simple suggestions on how to use the Web to
better manage your MSDS needs and simplify HazMat compliance. Using
the Internet to Find an MSDS You can start using the Internet right
now to search for, view, save and print MSDSs. Googling the term
“MSDS” returns
more than 27 million links, including hundreds of links to MSDS
portals.
While these portals generally do not provide MSDSs themselves, they
can steer you towards other sites that do. It should be noted that
you cannot blindly trust the content of all MSDS management Web
sites. Some “free” MSDS sites, many of which were launched during
the Internet boom of the
late 1990s, claim to have thousands of MSDSs, direct from the
manufacturer, and available at no charge. In reality, these Web
sites have often generated little revenue and maintain limited
staff.
Chances are that their MSDSs have not been kept current and many are
likely outdated.
Simplify MSDS
Management
Once you have located your MSDS, you can also use the Internet to
manage it, either through your own company Intranet, or by using an
MSDS management
tool hosted by a service provider.
If you publish your own MSDSs, you can make them visible to the
world via the World Wide Web. However, a poorly maintained website
containing outdated MSDS data can reflect negatively on your firm.
You should only do it yourself if you plan to run a fairly
sophisticated MSDS obtainment and information management process.
If you are a mid-sized company with more than one facility and
limited staff and dollars, you may want to consider outsourcing MSDS
management to a service provider. Service providers can generally
reduce your cost to manage MSDSs by at least 30 percent and increase
your MSDS compliance to near 100 percent.
Fact Checking and
the Web
The Internet can also be a valuable fact-checking resource. OSHA’s
Hazard Communication Standard (HCS) is designed to be a “performance
standard,” meaning that its requirements allow companies a certain
degree of flexibility in applying the standard to their particular
workplace.
While this flexibility can be an advantage to companies, allowing
them to design a hazard communication program tailored to their
needs, the guide-lines can also leave some users asking
questions.
Conducting a thorough search of the OSHA Web site (www.osha.gov)
answers some of these questions and can dispel some of the most
common myths about MSDS compliance.
Myth #1: “If a product is produced overseas, you need
to contact the foreign manufacturer for questions.”
OSHA has clarified in a letter of interpretation that products
produced and imported from overseas manufacturers must list the
importer or other domestic responsible party as the main contact for
additional technical product information. MSDSs forwarded without a
U.S. contact that can answer specific questions about the chemical
are not considered adequate by OSHA.
Myth #2: “An MSDS must include regulatory information
including NFPA, HMIS, and Transportation classification.” While the
MSDS can often be an excellent tool for accessing such information,
OSHA does not require it on MSDSs under the HCS. The HCS was written
to protect employees by educating them about the hazards of the
chemicals in their work environments. Therefore, just because
information required by the Department of Transportation or the fire
department isn’t
printed on the MSDS does not mean it is non-compliant.
If a company requires employees to identify this information from an
MSDS, it must provide additional training on how to classify
products to National Fire Protection Association (NFPA), Hazardous
Materials Information System (HMIS) and/or Transportation
regulations based on the physical and chemical property data
provided by the MSDS and other sources as necessary.
Myth #3: “Keeping the MSDS sent from the vendor on file is
all a company needs to do for compliance.” Actually, while the
standard does afford companies a great deal of flexibility
when applying the standard to their workplace, HCS compliance is a
bit more complex than just filing away a sheet of paper that may
come with a chemical delivery.
A written Hazard Communication program, including a hazmat inventory
must be maintained, container labeling must be addressed, and all
employees who may be affected by a particular hazardous material in
their work areas must be trained on how to access and read the MSDS
associated with the hazardous product in question. MSDSs are only
truly accessible — hence, making the company’s hazard communication
program compliant — if an employee can match the correct MSDS to the
product with which he or she is working.
A Valuable Resource
The Internet can be a useful and robust tool for busy EH&S
professionals. While properly acquiring and maintaining MSDSs is not
a small job that can be solved with a few simple clicks of the
mouse, the Internet can be a valuable resource for managing MSDS
needs.
FSM Michael
Beckel is with the 3E Company. For more information on MSDS
management, email
info@3ecompany.com
or call 800.360.3220.
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