A couple of weeks back, SafetyXChange did an article about whether it's against the law to computerize MSDSs'. I think it's important to also consider the practical problems of computerization and the need for paper backup. Let me tell you about some of my experiences.

The Scanning Setback

A company I used to work for switched over from a paper to a somewhat computerized MSDS system. It was a "subscription" system. And it didn't work so well.

They wanted all MSDSs' scanned to eliminate the paper. After countless hours of scanning and saving, we ended up with a huge file of MSDSs' that were mostly unreadable. (Of course, this took place before we could easily get MSDSs' in PDF form e-mailed to us.)

The Fax Fiasco

Then there was the next great idea. They decided to contract out with this company and arrange things so that all we had to do was phone an 800 number and an MSDS would be faxed to us.

It sounded like a good theory. But it had several drawbacks:

This subscription service also had a lot of holes. As part of the training I provided to orient members of my department to the system, I had each employee call the listed toll free number to request a fax of an MSDS for a particular substance. The service couldn't provide even one of the MSDSs' we requested.

Of course, I had rigged the deck by going back to the 30-year file and pulling trade names of products for companies I knew were no longer in business. I wasn't trying to sabotage anything. I just wanted to test the limits of the system. But my superiors weren't happy with what I had done because they had chosen the service provider. After they contracted with the provider, they told me to dispose of the old paper MSDSs'.

I didn't get rid of the paper files and never would. They were still there in the file cabinets when I left the company. I can only hope they're still there now - or at least there's some paper system in place now that I've been gone for so long.

What I Do Now

Today, I maintain paper MSDS files in my office. The office remains open at all times so workers can have access even when I'm not around. I also keep binders in the work area and update them regularly.

But I have integrated electronic components. I maintain an electronic database which is a shared file system. I keep an electronic list on Excel spreadsheets, sorted by "our" raw material number, trade name and manufacturer. Each spreadsheet contains a hyperlink to the MSDS, and a link to the manufacturer's website. This enables the chemists and other users to bring something up on their computers instantly for reference without having to take a file to get it copied. Everything, of course, is backed up on our server.

But the paper is there and always will be there and available as needed.

Conclusion

I have nothing against computerized MSDSs'. For many companies this is a very viable alternative to the paper mountain. Nor am I opposed to outside MSDS services or the companies that provide them. I'm just saying you have to think about all variables affecting availability including the possibility of power outages or phones being down. What I'm saying is don't throw out those paper files. They're important as a backup to the electronic system.

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AMEN
The Paper MSDS Is a Legal Requirement

By Glenn Demby

What Gary just said about the importance of maintaining paper MSDSs' to back up the electronic system isn't just sound practical advice. It's required by both U.S. HazCom and Canadian WHMIS laws for the very reasons Gary explains in his article.

The bottom line: You need to keep paper MSDSs' as a backup in case technical glitches or power failures shut down the electronic system.

HISTORIC MOMENTS IN WORKPLACE SAFETY

Is this an ancient MSDS?

The Invention of the MSDS

By Glenn Demby

The MSDS became a legal requirement in the 20th century. But Kansas State University Professor Samuel Kaplan says the concept dates back at least to the Egyptians. Archaeologists have unearthed writings describing the dangerous properties and proper uses of chemicals on the walls of tombs and in papyrus records more than 4,000 years old.

Centuries later, the Sumerians created crude forms of MSDSs' for the dyes they used. Greek and Roman scientists and physicians kept records cataloging the properties of the chemicals they worked with. Galen codified this knowledge in his works on human anatomy. Similar writings were created by members of Islamic, Indian, Chinese and other non-western societies.

The data contained in the modern MSDS (and methods of recording them) continued to develop over the centuries. But when did the MSDS document actually come into use?

According to Kaplan, by the middle of the 19th century, chemical and drug manufacturers began supplying their customers forms of data sheets describing the precautions and methods of handling their products. While researching NIOSH archives, Kaplan came across what he believes to be the earliest example of an MSDS - a 1906 writing by a firm called Valentine and Company. In 1946, the Manufacturers Chemical Association (the current CMA) began publishing "Chemical Safety Data Sheets."

Regulators & the Modern MSDS

Inevitably, governments started getting involved. Right after World War II, the U.S. Department of Labor published a series of profiles of dangerous chemicals for workers. The series was entitled "Controlling Chemical Hazards" and the first installment was about ammonia. In 1958, the U.S. Congress mandated chemical disclosure for dock workers under the Longshoremans & Harbor Workers Act.

The modern MSDS was developed in the 1960s by an industrial hygienist working for the DOL's Industrial Safety and Occupational Health Support Office. The first official form - Form No. LSB-OOS-4 - was added to the maritime safety regulations in 1968.

When workplace health and safety regulations were extended to all workers as part of the new OSHA law in 1970, Form No. LSB-OOS-4 became Form OSHA-20. In 1983, OSHA issued regulations mandating that manufacturers use an MSDS for all shipments of hazardous chemicals leaving their workplace. The requirement was expanded to cover all employers in 1987.

Conclusion

Of course, the MSDS isn't a uniquely American institution. Parallel versions of the MSDS are now required by almost all of the world's industrialized countries and efforts are being made to globalize standards and create a universal MSDS form that will work in all countries.

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