You will not believe this!
Incident # 1: An OSHA inspector said, “watch this” and he picked up the oldest most rusty can of spray paint he saw on the shelf and asked to see the Safety Data Sheet. Although we had a hundred SDS’s, we did not have this one. Smiling, he said “I knew it! I get them on that every time”.
Incident # 2: We had a forklift operator loading an empty trailer and was exposed to an unknown chemical residue from inside the trailer. After about two trips into the trailer, she began to have difficulty breathing and was having a skin reaction. EMS was called and off the Emergency Room she went. The doctors of course wanted to know what the chemical substance was. It took about 2 hours and numerous phone calls, but we finally identified the material. The MSDS was faxed to us and the doctors were able to treat her. The MSDS saved the day!
Incident # 3: Observed a construction worker applying a concrete sealant on a newly poured floor. The worker was not wearing any PPE, no protective gloves, no respirator, and no safety glasses. The label indicated the sealant was corrosive and emitted toxic fumes! The young man had no idea of the hazards, was not trained and did not have any PPE at his disposal. And the supervisor was his uncle who when confronted replied “mind your own business, he is my nephew, and I will not let him get hurt”. Can you believe that? We corrected the situation immediately.
HazCom is still one of the most cited OSHA regulations. And it is so easy to comply, it just takes a little time and effort.
Do # 1: Ensure you have a written hazard communication program.
Do # 2: Conduct the chemical inventory and update it at least once per year.
Do # 3: Obtain each SDS and make them available to all employees. It is rare that employees ask to see an SDS, but you can guarantee an OSHA Inspector will ask to see them.
Summary: Many companies are using on-line SDS management systems to save time, effort, and making compliance much easier. Using hard copies and 3-ring binders are fine for most companies, but when you have multiple sites and hundreds of SDS’s, consider a more high tech solution.