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November 19, 2018

Hazard Communication and SDS Management – The long-term view

Hazard Communication_1The Hazard Communication standard from OSHA has been around for a very long time. The end goal of a good hazard communication program is to make sure employees understand the hazards of the chemicals in their workplace and how to take appropriate precautions to prevent exposure.

 

The OSHA Hazard Communication Standard (HCS), now aligned with GHS (Globally Harmonized System of Classification and Labeling of Chemicals) provides a standardized and easily understandable approach to classifying chemicals and communicating hazard information on labels and safety data sheets.

 

In our conversations with Safety professionals wanting to improve their programs, justifying spending on a digital SDS information management system can be a struggle. EHS professionals can have difficulty justifying spending to executive management who are very good at saying No. We need to take the time to make sure overloaded executives fully understand the big picture. There are two primary areas of risk for the employer at play here, short term and long term. We will focus this article on long-term risks and cover off on short-term in a second article.

 

You can still find many organizations who trust a notebook with paper copies of SDS’s from their vendors. Some use paper and some use software solutions for data management. The reality is you can have a compliant program with paper, but here is the rub.

 

Fact One - Based on 2018 data from the US Bureau of Labor Statistics the average employee tenure is 4.3 years.

 

Long term within your organization your people will change. That change is generally faster for younger workers and slower for more mature workers, but one fact is clear your people will change. 

 

Fact Two - OSHA 1910.1020 Requires an organization to maintain employee exposure records for 30 years after the last day of its use. 

 

So, organizations should have accessible Safety Data Sheets, and or chemical inventory records which reveals where and when used and the identity (e.g., chemical, common, or trade name) of a toxic substance or harmful physical agent. There are lots of details in the rules but big picture you need good materials and inventory records to be prepared to handle requests from current employees seeking information based on the daily working environment, as well as requests from operations in the past.

 

With a US Average employee turnover of 4.3 years you can quickly see the long-term risk trusting poorly documented SDS and chemical inventory management can bring. This means your organization's safety manager will have changed six times, your chemical inventory manager six times, your HR manager six times. So banking on notebooks and the tribal knowledge of your staff is unwise knowing the duration the rules require you to track. Reminding business leaders about the records retention rules is quite important as the standard of care for most financial records (like your business taxes) is generally seven years.

 

For additional support for long-term risk, ask Siri, Alexa, or execute a quick google search for Toxic Torts and you will see an army of law firms looking for people who may have sustained an injury due to chemical exposure and educating them on their legal options. The cost of having your legal firm defend a case, regardless of the merit of the claim, will quickly exceed the amount you spend on a good SDS management solution, Chemical approval, and Chemical Inventory management.

 

The OSHA standard requires your organization to provide access to the record within fifteen (15) working days. Having rapid access to specific chemical facts makes it much easier to prevent or defend a case. But trusting your 30 years record management requirements to paper-based or poorly managed information is simply bad management.

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