(Approved, FLC Health and Safety Group, Nov. 30, 2004)
Safety Data Sheets (SDSs) which used to be called Material Safety Data Sheets (MSDSs) are intended to provide detailed chemical information regarding occupational exposure, emergency medical treatment, and environmental risk for materials sold into the commercial market. (Consumer products are not covered by SDSs.)
The OSHA 29CFR 1910.1200 Hazard Communication Standard (HCS) requires that employers provide each employee direct access to an SDS for each chemical present in his/her workplace. The HCS is a performance-based standard, which means that OSHA does not specify how to achieve compliance. Instead, OSHA issues the following compliance guidance to employers: (Letter dated 12/30/97 Manufacturer and employee responsibilities when providing SDSs electronically)
A later guidance letter (see Appendix 1) states:
In general, we have not allowed transmittal of hazard information over the telephone. However, if the employer is relying on telephone transmittal of hazard information only for the purposes of backing up the primary electronic system, and if the MSDS will be provided as soon as possible after the request was made, we would consider this system an adequate back-up to the primary system.
Employers are not required to provide SDS access for general office workers or for workplaces where exposure to hazardous materials is infrequent and incidental (e.g., a cleaning fluid used on an office machine three or four times annually, and otherwise stored in a cabinet or on a shelf). Also, products intended for the open consumer market are not included, even when they appear in the workplace.
While as a State of Colorado agency, Fort Lewis College is immune from OSHA enforcement, the College is required by the State to maintain comparable performance standards in worker protection.
Several organizations provide public searchable SDS libraries online that can be used for "paperless compliance" with the OSHA standard. These organizations invite manufacturers to submit their SDSs for posting to meet the OSHA requirement for providing free SDSs to customers. This also provides SDS Health Hazard Data and first aid information to medical and emergency responder's and to the general public as a public service. For employers who have a large variety of workplace chemicals present, these online libraries offer a powerful advantage over hard copy SDS collections because they can be electronically searched by manufacturer, brand or product name, common or IUPAC chemical name, or the universally unique CAS number, thus bypassing the common referencing/filing problems associated with large collections of paper SDSs.
When an employer uses computers to provide direct employee access, it is important that employees have direct access (not through a supervisor) to an appropriate computer and printer, along with adequate training.
The following information is based on actual test phone calls placed to these centers on a holiday afternoon. These are true 365/24/7 medical emergency services which can provide at least as much information as the Health Hazard Data and First Aid sections of an SDS..
Will provide Basic First Aid information and health Hazard Data for immediate response. Medical professionals can have on-the-spot phone conferencing with Center professionals. They will fax SDSs to the medical professionals. This is a true medical emergency hotline service and is likely the first response support service used by Mercy Medical Center, etc.
CHEMTREC® (Chemical Transportation Emergency Center) was established in 1971 by the chemical industry as a public service hotline for fire fighters, law enforcement, and other emergency responders to obtain information and assistance for emergency incidents involving chemicals and hazardous materials. For all emergency callers, will provide Basic First Aid information for immediate response. Materials experts are available to work with treating physicians at the receiving emergency facility. They will fax SDSs. This is a true medical emergency hotline service. Also see www.chemtrec.com.
All employees have direct access to the College network through a user name and password for obtaining personnel policies and other information, including pay records. In addition to networked computers in various shops and offices, the PPS Service Center maintains a general access networked computer with adjacent printers which any PPS employee may use without asking permission or other intervention.
The College provides links (see SDS Website Links below) to several searchable online SDS libraries, along with supporting links for general SDS and regulatory information. Using the simple search procedure, employees can locate an SDS by information from a container label (e.g., manufacturer, product or brand name, common or IUPAC chemical name, CAS number, properties, etc.)
All employees who would be subject to the OSHA HCS should be trained as appropriate in accessing the online libraries and retrieving an SDS. This does not include staff whose primary workplace is an office or office-like setting.
A supervisor has the option to provide a paper collection for a workplace by downloading SDSs from the searchable online SDS libraries or by retaining the paper copies normally shipped with the product.
Emergency backup access for medical response is provided by posting toll-free phone numbers for Rocky Mountain Poison and Drug Center (1-800-222-1222) and ChemTrec (1-800-424-9300). These 365/24/7 services will work with emergency responders (including College Public Safety and Campus Health Center personnel) to assist on-the-scene response, as well as support the emergency work of Mercy Medical Emergency Room personnel.
Internet links to public online SDS libraries are accessible through a Need an SDS? page on the College Hazardous Materials Management site. The text on this page may be copied into a desktop file on any campus computer to create a direct mechanism for reaching the online libraries. Providing redundancy through several sites on several servers guards against being blocked by temporary site inaccessibility.
While the College is not required to provide students (unless employed by the College) direct access to SDS information, students may find such information useful, particularly in certain studio and laboratory settings. Each enrolled student has access to the campus network and thus can access SDSs using the Need an SDS? page on the College Hazardous Materials Management site. Access information is posted in appropriate studios and laboratories.
Appendix 1. OSHA Guidance Letter dated 10/13/1998 - Using the telephone to back-up electronic access to MSDSs.
October 13, 1998
Mr. Mark Hoffman
6494 Latcha Road
Walbridge, Ohio 43465
Dear Mr. Hoffman:
Thank you for your letter of July 10, to Ms. Jule Jones, Office of Construction Standards, Directorate of Construction. Your letter has been referred to the Office of Health Compliance Assistance, Directorate of Compliance. Please excuse our delay in responding. Your letter asked the following question:
Is it acceptable, as a back-up system for electronic access, for employees to request a Material Safety Data Sheet (MSDS) over the telephone? The MSDS would be delivered to the employee as soon as possible, but no longer than two hours later.
MSDSs are an important part of the safety and health information in the workplace. The Hazard Communication Standard (29 CFR 1910.1200) requires that MSDSs "are readily accessible during each work shift to employees when they are in their work area(s)." In this regard, the Occupational Safety and Health Administration has interpreted the term "readily accessible" to mean "immediate" and would consider a two hour interval between an employee's request for an MSDS and receipt of the information to fall short of this criterion.
In a telephone conversation with a member of my staff, you further asked whether hazard information transmitted orally over the telephone would be considered adequate as a back-up system in the event of failure of the primary electronic system.
We trust this answers your questions. If further information is needed, please feel free to call our Office of Health Compliance Assistance on 202-219-8036.
Richard E. Fairfax
Directorate of Compliance Programs