Tuesday, September 29, 2015

Steps to an effective hazcom program for employers

4. Maintain Safety Data Sheets cont'd

Chemical manufacturers and importers are required to obtain or develop an SDS for each hazardous chemical they produce or import. Chemical manufacturers, importers, and distributors are responsible for ensuring that their customers are provided a copy of these SDSs, at the time of the first shipment, and when an SDS is updated with new and significant information. Employers must have an SDS for each hazardous chemical which they use. Employers may rely on the information received from their suppliers unless they know the information is incorrect. If you do not receive an SDS automatically, you must request one as soon as possible. If you receive an SDS that is obviously inadequate, with,
for example, blank spaces, you must request an appropriately completed one. If your request for an SDS or for a corrected SDS does not produce the information needed, you should contact your
local OSHA area office for assistance in obtaining the SDS. Employers must maintain the current
version of the SDS; if a new SDS is received with a shipment, they must maintain and make available
the new SDS.

The SDSs must be in English. Many larger manufacturers also produce SDSs in other languages. If you have workers who speak language(s) other than English, you may be able to obtain SDSs in those languages to ensure effective hazard communication.

Employers must maintain copies of SDSs in their workplaces, and must ensure that SDSs are readily
accessible to workers when they are in their work areas during their work shifts. This accessibility
may be accomplished in many different ways. You must decide what is appropriate for your particular workplace. Some employers keep the SDSs in a binder in a central location (e.g., in a pick-up truck on a construction site). Others, particularly in workplaces with large numbers of chemicals, provide access electronically. However, if access to SDSs is provided electronically, there must be an adequate back-up system in place in the event of a power outage, equipment failure, or
other emergency involving the primary electronic system. As long as workers can get the information
when they need it, any approach may be used. When workers must travel between workplaces during a work shift, SDSs may be kept at the primary workplace facility. No matter what system is used,  employers must ensure that workers and medical personnel can immediately obtain the required information in an emergency.

In order to ensure that you have a current SDS for each chemical in the plant as required, and that worker access is provided, OSHA’s CSHOs will be looking for the following items in your program:

1. Designation of person(s) responsible for obtaining and maintaining the SDSs;
2. How such sheets are maintained in the workplace (e.g., in notebooks in the work area(s) or electronically), and how workers obtain access to them when they are in their work area during the work shift;
3. Procedures to follow when the SDS is not received at the time of the first shipment;
4. An SDS for each hazardous chemical in the workplace, and training of workers that includes review of SDS format and use.

For employers using hazardous chemicals, an important aspect of the hazard communication program is to ensure that someone is responsible for obtaining and maintaining the SDSs for every hazardous chemical in the workplace. To ensure that your hazard communication program improves safety and health with regard to chemical use, you should review the SDSs, and use the information to choose the needed protective measures to prevent or reduce exposures in your workplace. SDSs should be used to evaluate your workplace, and establish a plan to ensure it is safe. The following is a section-by-section description of the information required for each part of the SDS from Appendix D of HazCom 2012. Become familiar with the information available in each section of an SDS so that you will be able to more quickly access this information in an emergency and make better use of the data available.

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