Loading ...4 MSDS Precautions to Take, Part 2 of 2
Getting your MSDS act in order isn't just a HazCom/WHMIS obligation. It can quite literally be a matter of life and death to the workers who rely on the completeness and accuracy of the information the MSDS contains. Here are four steps you can take to protect your organization, its workers and yourself.
1. Appoint Central MSDS Administrator
OSHA experts say it's important to designate a point person who's responsible for keeping track of MSDS. This person should:
- Make sure there's a current and complete MSDS for each hazardous substance at your workplace;
- Keep an accurate log of hazardous substances; and
- Ensure that workers have ready access to MSDS.
2. Keep MSDS Database Up to Date
Chemical manufacturers and importers are required to send you an MSDS at first shipment and whenever there's a change. Even so, MSDS information at many companies is out of date. That may be because manufacturers send only the original MSDS and not the revised version. Or it may be because the revised MSDS gets lost or misplaced at shipment, especially if the person who takes shipment isn't familiar with the MSDS system.
Compliance Strategy: Go through each MSDS at your workplace and make sure it's current. If it's more than a year or two old, you should ask the manufacturer to send a revised one or get it from the company's website. Also try: www.msdsonline.com and www.hazard.com/msds/index.php.
3. Make Sure MSDS Has All Required Information
An MSDS may not list all the information the law requires, especially if the MSDS was prepared on site. Sometimes the omitted information can be critical, like in the Chesterton incident we discussed last week. So go through each MSDS at your workplace and ensure it contains:
- Chemical and common names of all ingredients considered health hazards;
- Physical and chemical characteristics of hazardous chemicals such as vapor pressure and flash point;
- Physical hazards such as potential for fire or explosion;
- Health hazards including signs and symptoms of exposure and medical conditions that exposure may aggravate;
- Primary routes of entry into human beings;
- Permissible exposure limits;
- Whether the chemical is considered a carcinogen;
- Precautions for safe use and handling including appropriate protective measures during repair and maintenance of contaminated equipment and procedures for spills or leaks;
- Control measures such as appropriate protective equipment and work practices;
- Emergency and first aid procedures; and
- Date of preparation of the MSDS and contact information of company or person who prepared the MSDS.
Compliance Strategy: It usually takes at least three pages to fit in all this information. If an MSDS is shorter than three pages, it could be an indicator that certain information is missing.
4. Avoid Inconsistencies and Techno-Babble
Check each MSDS for inconsistencies (for example, calling a product a liquid in one place and a gas in another). Also be on the lookout for an overload of dense technical jargon. Remember that an MSDS won't help if workers can't understand it. To make the MSDS easier to read, consider creating a "summary sheet" that highlights the product's properties and hazards. But be careful: If you change the substance of an MSDS prepared by a manufacturer, you may become liable for the contents.
Conclusion
One more word of advice: To make the MSDS easier to understand, consider creating a "summary sheet" that highlights the hazards of specific chemicals. But attach the summary to the actual MSDS so workers have access to all the information if they want it.
MSDS QUIZ
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Spot the Mistake
Safety director Matt Hazard takes inventory of all hazardous substances that the company uses in the workplace and verifies that there's a complete, up-to-date MSDS for each one. He assembles all of the MSDSs into a looseleaf binder and keeps it in his office. Although Matt keeps the office locked, he goes out of his way to remind workers that he'll gladly give the binder to anybody who asks to see it.
QUESTION
Which one of Matt's acts or omissions violates HazCom/WHMIS?
- Not independently verifying the accuracy of the information in the MSDS
- Not preparing a company version of the MSDS
- Keeping the MSDS binder in his locked office
- Keeping MSDSs in a paper binder rather than a computer system
ANSWER
C
EXPLANATION
OSHA/WHMIS standards require employers to make the MSDS readily accessible to any worker who may be exposed to hazardous chemicals and substances. Although it doesn't specify the exact method to use, OSHA and Canadian OHS authorities interpret "readily accessible" to mean that workers should have access to the MSDS when they're in work areas during workshifts. Workers should have access to that information themselves and not through somebody else. Keeping MSDS in the office of a safety director or any other individual is problematic because:
- The safety director's office may be far from the shoproom floor or even off the premises;
- The office is likely to be kept locked during certain shifts; and
- Workers shouldn't have to ask the safety director or anybody else for permission or make an appointment to see the MSDS.
WHY WRONG ANSWERS ARE WRONG
A is wrong because employers may rely on MSDS information they get from their suppliers without having to analyze or evaluate a hazardous substance independently.
B is wrong because companies can use the MSDS they get from a supplier unless they produce the chemical themselves.
D is wrong because while making MSDS sheets available to workers via a computer terminal is an option (provided that the employer takes certain steps like making sure the equipment constantly works), it isn't mandatory.
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