Q: We use an electronic MSDS access system. Are there any special training requirements we need to know about?
A: The most important training requirement beyond those listed in the standard would be teaching staff members how to use the electronic system to access the required information (how to launch the program, any login requirements (e.g. a password), how to navigate the system to find the desired document, etc.) According to OSHA Hazard Communication standard (29 CFR 1910.1200), MSDSs must be “readily available,” so I wouldn’t be surprised if an OSHA inspector asked one of your staff members to demonstrate the use of the system. Another aspect you’ll need to include is how to get an MSDS in the event of an electronic system failure, such as a power outage. Is there a backup generator to power computers on the system? Is the information available by phone? Are there (current) paper copies of the MSDSs somewhere in the office?
*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities  by Sarah E. Alholm, MAS.