Tackling OSHA’s Top 10 Citations: Q & A: Safety Data Sheet Availability
The following is an excerpt from Tackle OSHA’s Top 10.
Hosted by Chief Safety Officer Jill James, you can listen to the webcast on demand.
Q: “On the SDS sheets, OSHA reads the SDS's have to be readily accessible or maybe readily available. There's nothing that says they have to be printed or even available electronically - nothing specific. This means the SDS can be faxed to you from an online database per some vendors. Correct?”
A: No, it doesn’t. Here’s the test: if an OSHA inspector walks into one of your facilities and asks to see a SDS, they aren’t going to wait for a fax to come through—you’ll be cited, most likely.
The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)
Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the material safety data sheets may be kept at the primary workplace facility. In this situation, the employer shall ensure that employees can immediately obtain the required information in an emergency.
Safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in their work area(s).
Safety data sheets shall also be made readily available, upon request, to designated representatives, the Assistant Secretary, and the Director, in accordance with the requirements of § 1910.1020(e).
You also need the ability to produce your written HAZCOM program whenever an employee requests to see it…
The employer shall make the written hazard communication program available, upon request, to employees, their designated representatives, the Assistant Secretary and the Director, in accordance with the requirements of 29 CFR 1910.1020 (e).
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