Is Electronic SDS Management Permitted?
Yes, OSHA has consistently maintained that employers may use electronic systems to provide required Right-to-Know (RTK) access to SDSs. Options for online electronic management and employee RTK access include using a company website or intranet, or contracting with an off-site, web-based software service provider.
Electronic SDS access is a great solution for the challenges of the modern workplace, including multi-employer worksites at which host employers would need to make SDSs available to temporary and contracted workers in addition to their own employees. Employers who go this route just need to make sure they’re doing it right.
No Internet Searches Allowed
It’s very important to make sure you’re providing access to the specific SDSs for your chemical products from your specific product suppliers, and that you’re doing so via a formal system and not simply using a popular search engine such as Google®, whereby you’re sending employees out to the internet to try and view and obtain SDSs.
Doing so is problematic for many reasons and is not considered a compliant option for online SDS management and employee RTK access. This also means you cannot simply send employees out to use a general “find an SDS” search tool provided by a third party. OSHA says you must have a curated library of SDSs that match your specific inventory of chemicals.
Whether you choose to manage your SDS documents using your own website or that of an online SDS management service provider, you must ensure your system meets OSHA’s electronic online SDS management compliance criteria.
VelocityEHS pioneered online safety data sheet management decades ago with its Chemical Management capabilities and continues to provide employers like you with the industry’s #1, reliable, compliant solution for your SDS and chemical inventory management needs.
Online SDS Management Compliance Criteria
Electronic access systems for SDSs are a great way to ensure that your SDSs are available to your workforce quickly and easily, as long as you are meeting the following compliance criteria:
- You are not relying on internet searches, including searches on popular search engines like Google®, for employees to retrieve SDSs
- You are making the SDS documents available through your own website/intranet or have contracted with a third-party vendor to use an SDS management system, such as VelocityEHS’ Chemical Management Capabilities
- All your covered employees have adequate access to the electronic system, without restrictions
- You have a backup system or process in place for instances when the primary electronic system may be inaccessible due to potential foreseeable issues such as power outages, as well as emergencies like natural disasters. VelocityEHS Chemical Management includes multiple backup options, making it easy to comply
- You are able train employees on how to access SDSs, through both the primary and backup systems
- You are able to provide hard copies of your SDSs to employees or OSHA representatives upon request, as well as to first responders and medical personnel in cases of emergency (NOTE: VelocityEHS offers around-the-clock access to critical chemical safety information online, offline and through our globally recognized Emergency Response Services hotline)
And remember, you need to describe your methods of providing SDS access in your Written HazCom plan, including both your primary and backup systems, and you need to describe how you provide your SDSs to any temporary or contract workers.
The First Line of Defense in Workplace Chemical Safety
Chemical container labels are the most direct, most immediate means of communicating chemical hazards to the workers who use them. Whether you’re a manufacturer, importer, distributor, or end-user of hazardous chemicals, it’s absolutely critical that you fully understand your GHS labeling requirements to not only ensure compliance with applicable regulations but to safeguard your employees and your workplace.
Shipped/Supplier Labels vs. Workplace/Secondary Labels
There are two types of GHS labels; shipped container labels sometimes referred to as supplier labels, and workplace container labels otherwise known as secondary labels.
If you are a supplier (manufacturer, distributor or importer) who ships hazardous chemicals to downstream customers, you need to create shipped labels and affix them to the immediate containers of those chemicals prior to being transported. In general, there are six label elements that all chemical suppliers must include on GHS shipped container labels. These six elements are:
- Supplier Identification
- Product Identification
- Signal Word
- Hazard Statements
- Hazard Pictograms
- Precautionary Statements
You may also be required to include supplemental information on the shipped/supplier label, and may need to furnish labels in specific languages or in multiple languages. For example, Canada’s WHMIS and Hazardous Products Regulations (HPR) require suppliers to provide labels in both English and French translations. Be sure to consult applicable regulations (OSHA HazCom, WHMIS, EU CLP, etc.) to determine what GHS elements and other hazard information must be present on your shipped/supplier container labels.
Workplace/ Secondary Container Labels
Secondary/workplace containers are defined as any containers used to transfer hazardous chemicals from their original shipped/supplier container for subsequent use in the workplace. GHS requirements for the secondary/workplace container labels are less prescriptive than those for shipped container labels, and specific requirements may differ substantially from country to country.
For example, US OSHA’s HazCom Standard (HazCom 2012) states that workplace/secondary labels must either replicate the information on the shipped container label or contain some combination of GHS label elements that effectively provides employees with the specific information regarding the physical and health hazards of hazardous chemicals in the workplace.
Smart Labeling Solutions
VelocityEHS Chemical Management gives you the ability easily design and print GHS chemical container labels—helping you to simplify compliance and ensure your workers have immediate access to clear, accurate chemical hazard and safety information. Our intuitive labeling interface lets you select the desired label elements directly from the corresponding product SDS, then instantly generate GHS labels in multiple pre-built and custom label formats to accommodate the full range of container sizes and types throughout your workplace.
VelocityEHS Chemical Management features seamless integration with the leading chemical container labeling solution providers including Avery, Brady and Graphic Products, giving you the most versatile and user-friendly container labeling capabilities available. Once you’ve designed and formatted your container labels, you can instantly print them directly within your VelocityEHS Chemical Management account, saving you time and money.