The Dangers of a Large, Unorganized SDS Library

Any successful business needs a good strategy to compete and win in the marketplace. While many enterprises place great emphasis on product quality and marketing, regulatory compliance can be overlooked and under-emphasized. Often, the warning signs of non-compliance can be subtle, much like the subtlety of the “check engine” light in your car; but ignoring these warning signs can have profound consequences, whether driving a car or running a business.

One warning that your business may be non-compliant is if it has a large, unorganized library of Safety Data Sheets (SDS). In fact, “hazard communication” violations, such as non-compliant SDSs, are one of the most commonly cited violations by OSHA—and having a large, unorganized library of them, is a sure way to initiate inquiry, if not eventual citation, during an audit.

So why would a large, unorganized library of SDSs cause OSHA to issue you a citation? Well, first, OSHA requires that SDSs be “readily accessible,” meaning that they must be immediately retrievable during an audit. If you must thumb through a massive binder, only to find that your phosphoric acid SDS is nowhere to be found—you have a problem. If you’ve made the upgrade to an electronic library and your search for a phosphoric acid SDS returns 20 results, you still have a problem, unless your employee can quickly identify the correct one. If Joe must first call Carol, who then must call Sue, to get the most recent version of the SDS—once again, you will have a problem.

Not only must SDSs be readily accessible, but they must be current and representative of the actual inventory of chemicals at your site. In fact, the scope of OSHA’s Hazard Communication Standard, as defined in 29 CFR 1910.1200(b)(1), is to provide information “about the hazardous chemicals to which [employees] are exposed.” And realize that exposure to Dow Chemical’s phosphoric acid may not be the same as exposure to DuPont’s phosphoric acid, hence why simply using a “generic” library (offered by some companies), containing a random SDS from all possible chemicals known to man, is still an OSHA violation. Why? Because each SDS—even for the same chemical—may have a different hazard classification, different label elements, different PPE requirements, etc.; you must provide the SDS for the exact chemical that your employees may be exposed to, not an SDS for the same chemical, but by a different manufacturer.

2018 penalties for Hazard Communication non-compliance are now up to $12,934, per violation. Even a small business may have dozens, if not hundreds of SDSs, leading to potentially dozens or hundreds of violations, each with a price tag of >$12k, resulting in fines of hundreds of thousands of US dollars, or more; for a small business, this could be devastating.

Thanks to its ease of navigation and immediate retrieval ability, electronic cloud storage solutions, such as those offered by Global Safety Management, can help you avoid this scenario altogether, improving your organization and audit preparedness, and saving you money in the process.

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