Safety Data Sheets (SDSs) at Fort Lewis College

(Approved, FLC Health and Safety Group, Nov. 20, 2025)

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 Federal OSHA Hazard Communication Standard

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)

  1. The employer must ensure that MSDSs are readily accessible and that there are no barriers to employee access. This includes ensuring that reliable devices are readily accessible in the workplace at all times.
  2. The employer must ensure that workers are trained in the use of these devices, including specific software.
  3. The employer must ensure that there is an adequate back-up system for rapid access to hazard information in the event of an emergency including power-outages, equipment failure, on-line access delays, etc.
  4. The employer must ensure that the system of electronic access is part of the overall hazard communication program of the workplace.
  5. The employer must ensure that employees are able to obtain hard copies of the SDSs, if needed or desired.
  6. In case of emergency, the employer must ensure that mechanisms must be immediately available to provide emergency response personnel with hard copies of SDSs.

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.

State of Colorado Standard

As a State of Colorado organization, Fort Lewis College is immune from OSHA enforcement; the College is required by the State to maintain comparable performance standards in worker protection. The CDPHE requirements are higher or equal to OSHA requirements and they have the same enforcement ability as the EPA.

Using SDSs for emergency medical treatment

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..

Rocky Mountain Poison & Drug Center
1-800-222-1222

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
1-800-424-9300, Ext. 1

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.

How does FLC meet the performance standard?

Direct employee access

All employees have direct access to the College network through a username 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 a link to the SDS Database, 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

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.

SDS website link

To find an SDS, use the searchable SDS Database. The SDS can be printed or 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.

SDS access for students

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 searchable SDS Database. Access to information is posted in the appropriate studios and laboratories.