Editor’s note: This post originally appeared on Mac’s Safety Space .
Every once in a while I like to take questions from the studio audience and today I’d like to address the question of where one has to have copies of their Safety Data Sheets (in the interest of history, I’m going to resist using the “old” term Material Safety Data Sheets) in each department.
So, the short answer is “no,” there is no specific requirement to have copies of the SDS in each department. But there is some contextual stuff that requires a bit of diligence, so I think a quick review of the language in the Hazard Communications Standard may be useful (the section of the Standard dealing with SDS is 1910.1200(g) – we’re just looking at the portion that discusses how employers are expected to manage them):
1910.1200(g)(8)  The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)
1910.1200(g)(9)  Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the material safety data sheets may be kept at the primary workplace facility. In this situation, the employer shall ensure that employees can immediately obtain the required information in an emergency.
1910.1200(g)(10)  Safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in their work area(s).
So, basically it all really boils down to that last statement. You need to have SDS information for each hazardous chemical and that information has to be readily accessible to employees when they are in their work area(s). As I think we’ve discussed in the past (but if we haven’t, we’re going to, starting now), the Hazard Communication Standard is a performance standard (much like many of the Joint Commission standards). The HazComm Standard does not specify much in the way of compliance strategies, but rather focuses on establishing certain expectations and then each organization has to figure out how to meet those expectations from an operational standpoint. You can go about this pretty much any way that you want—as long as you can effectively provide access to SDS information for employees. If you can effectively provide access without having copies of SDS at the department level, then that’s what you can do. And if you can’t, then you have to come up with a strategy that does—which for the department-level access means copies of the SDS in the department. And to keep things on a front and center kind of standing, I might suggest that the effectiveness of the process for providing access to SDS information would make a very good performance measure upon which to evaluate the effectiveness of your Hazardous Materials and Waste Management program. Test the process—see if folks can retrieve the information they need without too much difficulty. If it’s a web-based program, ask them to show you how they work the process. Fax on demand? Same thing—have staff show you the process works. That way you “know” that you have an effective process.