By Phil Molé, MPH
Ask an employer what their chemical management system does, and there’s a good chance the first answer you’ll hear is, “It stores our Safety Data Sheets (SDSs).”
That’s understandable. Maintaining an up-to-date SDS library is one of the most visible and familiar requirements of OSHA’s Hazard Communication (HazCom) Standard alongside other global regulations, such as Canada’s Workplace Hazardous Materials Information System (WHMIS). Employees need quick access to safety information, emergency responders rely on SDSs during incidents, and organizations are responsible for ensuring those documents remain current.
But here’s the problem. An SDS library by itself is not a chemical management program.
An SDS tells you about an individual chemical product. Effective chemical management helps you to understand your entire chemical landscape and use that information to make better decisions about safety, compliance, and operations. In other words, SDS management is just the foundation. The real value comes from everything you build on top of it.
SDS Management Is the Starting Point
There’s no question that SDS management is essential. SDSs contain critical information about a chemical product’s ingredients, hazards, safe handling procedures, required personal protective equipment (PPE), first aid measures, storage requirements, and emergency response recommendations.
Without accurate and accessible SDSs, organizations can’t fully meet the requirements of HazCom or give workers the information they need to work safely.
However, storing thousands of SDSs in a database doesn’t automatically improve chemical safety. If your only interaction with those documents is searching for one after an incident or inspection, you’re missing much of the value they contain.
Modern chemical management begins by asking a broader question: What can we learn from all this chemical information?
Know Your Chemical Inventory
One of the requirements of many workplace chemical management standards, including HazCom, is for employers to have a chemical inventory: a list of all hazardous chemicals at their facility. Under HazCom, this needs to be an appendix to the site’s written HazCom Plan. There’s good reason for this because every robust chemical management program starts with a complete and accurate chemical inventory.
Understanding which products are present across all your facilities, where they’re located, what types of containers they’re stored in, and what quantities you have is critical. You also need to track movement of those chemicals, including how much of each chemical you use over the course of the year, so you can evaluate whether you’re exceeding usage thresholds for Toxic Release Inventory (TRI) and other use-based chemical reporting standards.
Just as importantly, it means understanding the ingredients inside those products.
Many compliance obligations and workplace risks are tied to individual chemical constituents rather than product names. For example, organizations may need to identify products containing poly and perfluoroalkyl substances (PFAS), Hazardous Air Pollutants (HAPs), Extremely Hazardous Substances (EHSs), Proposition 65 chemicals, REACH Substances of Very High Concern (SVHCs), or chemicals with occupational exposure limits (OELs).
The added difficulty is that many chemical products have names that tell you nothing about what’s in them. Suppose you have “Green Coat B” or “Easy Kleen Solvent #2.” Will usage of those chemicals potentially exceed reporting levels for Form R? Will storage exceed thresholds for Tier II reporting? Do you need to conduct indoor air sampling to evaluate whether airborne concentrations exceed OELs? You need to know what’s in the products before you can answer those questions.
Trying to uncover that information by manually reviewing hundreds or thousands of SDSs is tedious and time-consuming. You’d have to read all those documents, highlight the ingredients of concern, check them against regulatory lists, and then tally storage and/or usage numbers. This process isn’t just difficult, but also prone to error. A baseline level of knowledge is needed for users to highlight the right things without missing chemicals that are on one or more radar screens.
The name for this process is chemical ingredient indexing and the good news is that it can be done quickly, easily, and accurately when it’s automated through software. A chemical ingredient indexing service using AI can further take the error and drudgery out of indexing, so you can concentrate on the insights.
Ingredient-level visibility allows EHS professionals to quickly identify chemicals of concern, understand where they’re used, and prioritize actions before they become larger compliance or operational issues.
Leverage Chemical Information to Make Better Management Decisions
Knowing what’s in your facilities is valuable. Using that information to improve decision-making is even more valuable.
The most mature chemical management programs don’t simply answer, “What chemicals do we have?” They also provide the insights about, “What should we do about them?”
For example, organizations can use chemical data to:
- Identify opportunities to replace hazardous chemicals with safer alternatives
- Inform chemical hygiene plans and sampling plans for industrial hygiene
- Eliminate duplicate or obsolete products
- Standardize chemical purchasing across multiple facilities
- Demonstrate chemical governance to internal and external stakeholders, including customers, investors and value chain partners
- Support sustainability and environmental initiatives
- Prioritize reviews of the highest risk chemicals
Consider the issue of PFAS, also known as forever chemicals. For many years, companies incorporated PFAS into the manufacture of food packaging, non-stick cooking utensils, firefighting foam, and other common commercially available products. In about the last decade, research has made the public aware of the harmful effects of PFAS on human health and the environment, and the resistance of PFAS in landfills to biodegradation, which makes them persistent, bioaccumulative toxins (PBTs).
As a result, agencies around the world have passed regulations regarding PFAS, and companies have been asking potential value chain partners for evidence that they’ve taken steps to identify and at least reduce, if not eliminate, PFAS in their inventory. The ability to produce that evidence can make the difference between value chain partnerships continuing or ending, or maybe never even starting. In this way, lack of insight into your chemical inventory isn’t only a safety risk or environmental risk. It’s also a reputational risk, a business continuity risk, and for all these reasons, a financial risk.
Modern software-driven chemical ingredient indexing that uses AI to identify and summarize information about PFAS in your inventory can give you the visibility you need to get out ahead of regulations and workplace safety risks and make smarter decisions.
Instead of functioning as a digital filing cabinet, a modern chemical management system becomes a decision-support tool that helps organizations proactively reduce risk.
Compliance Goes Beyond SDSs
Another common misconception is that maintaining SDSs satisfies most chemical compliance responsibilities.
The truth is that many important obligations depend on having accurate inventory and ingredient data and using it both internally and externally.
Consider container labeling. OSHA requires employers to ensure that all chemical containers are properly labeled, so workers can quickly identify hazards, and that doesn’t just apply to shipped containers, including the original containers of the chemical provided by suppliers.
Organizations also need effective processes for labeling workplace containers, which are secondary containers, such as benchtop solvent spray bottles used throughout daily operations. Under HazCom, an employer needs to ensure that their workplace container labeling system, including the label itself plus supplemental info such as work instructions, signage, and training, effectively conveys all the hazard information on the shipped container label to employees within their shift.
The best practice for workplace labels is to just replicate the shipped label, which is often possible unless the label is small, in which case the employer may provide abbreviated hazard information as indicated by HazCom.
All of this is difficult in practice, because many employers lack fast, accurate and consistent methods for generating workplace container labels, and so many containers either remain unlabeled or incompletely labeled. This causes compliance issues. But it also creates additional risks, like exposing workers to dangerous chemicals, while being unaware of proper safety protocols, including proper ventilation, avoiding sparking tools, and proper personal protective equipment (PPE).
Regulatory reporting presents another challenge. Programs such as Tier II reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA) and Toxic Release Inventory (TRI) Form R reporting rely on accurate information about chemical quantities, storage locations, and hazardous ingredients.
You not only need to track storage and usage amounts of those chemicals but also identify chemicals that have lower reporting thresholds. For example, every PFAS added to the TRI list to date has a threshold of only 100 pounds whether processed, manufactured or otherwise used, compared to the 10,000 pound otherwise used/25,000 pound manufactured or processed threshold for most other TRI chemicals. EHS chemicals listed in 40 CFR Part 355 require reporting at only 500 pounds or the chemical-specific threshold planning quantity (TPQ), whichever is lower.
Without reliable inventory data at the ingredient and container level, these reporting processes often become labor-intensive exercises involving spreadsheets, manual calculations, and extensive document reviews.
Organizations with integrated chemical management programs can streamline many of these activities because the necessary information is already organized and accessible.
Don’t Forget Your People
Chemical management isn’t just about managing information, or just about maintaining compliance, as important as those things are. It’s about protecting workers.
Those of us old enough to remember what life was like before OSHA’s HazCom Standard (author included) know this all too well. OSHA issued the first version of the HazCom Standard in 1982 and expanded it in 1987 to apply to all of general industry. Prior to the HazCom Standard, employees routinely worked with chemicals they didn’t even know the identity of, let alone the specific storage and handling precautions to work with them safely, or symptoms and first aid procedures for exposure.
While working in an occupational health and safety clinic in the mid-1990s, I talked to a gentleman who’d spent most of his long career working with chemicals before the HazCom Standard. His job had been to operate a “dip tank,” a metal tub of solvent into which he’d immerse greasy parts with his bare hands, place the parts on a rack to dry, and repeat countless times over an 8-hour shift. He only found out years later that the primary ingredient in the degreasing solvent was toluene, which can cause various chronic symptoms due to overexposure, including destruction of mammalian cells in the brain responsible for short-term memory.
Because suppliers hadn’t provided information about the chemical to his employer, he had no protection from exposure and suffered the maximum health effects. It became clear over the course of our time with him that he had little or no short-term memory, because while he could accurately recall details of his work experience from 20 years prior, he couldn’t remember what he’d had for breakfast, or even how he’d gotten to the clinic. It also became clear that his wife, who’d accompanied him to the clinic, was doubling as his caretaker.
Regulations like HazCom only exist in the first place because of an identified need to prevent potentially life-changing health effects like this. They’re essential to maintaining a baseline level of workplace chemical safety. For example, HazCom requires employers to provide site-specific training on HazCom that discusses the background of the Standard and employer requirements, including details about the specific chemical hazards present onsite, the method of providing access to SDSs, and the workplace container labeling system in place.
Further, training is only effective if other components are effective. For instance, you can’t train your people on your workplace container label system if your system is inconsistent. And you can’t train workers about all chemical hazards in the workplace if you haven’t identified all the hazards because all ingredients of concern are not identified.
When you have a robust chemical management system, on the other hand, everyone from supervisors and EHS professionals to company leadership can make better decisions because they’re working from the same, up-to-date chemical information.
Building a More Complete Chemical Management Program
As you’ve hopefully learned by this point, there’s a lot more to chemical management than SDS management. While you absolutely need a way to maintain your SDS library and provide your people with access, an effective chemical management program also consists of:
- An up-to-date chemical inventory list containing information about every hazardous chemical at your site.
- Chemical ingredient indexing, to augment your chemical inventory list by identifying all components of chemical products, and then to cross-reference them against regulatory lists to flag ingredients with specific concerns.
- A container labeling system, including an effective and sustainable method for labeling secondary, or workplace containers.
- A written HazCom plan, functioning as a site-specific playbook for how you manage hazardous chemicals in your workplace.
- A workplace training program, aligned with the written Plan, that provides your entire workforce with information they need to work safely with chemicals, including an overview of chemical hazards present, the details of your SDS access system, a description of your workplace labeling system, and information about employer responsibilities under HazCom.
The challenge is that as organizations grow, all aspects of chemical management become increasingly complex. More facilities, more suppliers, more products, and more regulations create more opportunities for gaps in visibility and compliance.
That’s why leading organizations are moving beyond standalone SDS libraries toward integrated chemical management programs that connect SDS management with inventory tracking, ingredient intelligence, regulatory reporting, container labeling, and employee training.
Rather than maintaining disconnected systems and spreadsheets, they establish a single source of truth for chemical information that supports compliance, while improving day-to-day decision-making. They’re doing this through benefits of best-in-class chemical management software that brings these often-disparate parts together, giving you the governance needed to surface and act upon insights,
SDS management will always remain a critical part of workplace Hazard Communication. But it’s only one part.
The organizations that get the greatest value from their chemical management programs don’t simply collect chemical information. They use it. And that’s what transforms chemical management from a documentation exercise into a strategic advantage for protecting workers, reducing risk, and strengthening compliance.
Take the Next Step Toward Complete Chemical Management
Our Chemical Management solution, part of the Accelerate® Platform, gives you visibility and control to stay ahead of compliance, act quickly before risks escalate, and keep every shift safe.
Yes, you can maintain an up-to-date SDS library and provide access from anywhere, but that’s just the beginning. From support for workplace container labeling to container-level tracking and inventory mapping to our machine language powered chemical ingredient indexing service, including our AI PFAS Indicator, you’ll finally have all the governance you need in one place.
