Guidelines For The Proper Use Of Safety Data Sheets

It is imperative that you prevent complacency from spreading throughout your hazard communication programme.

The date that marked the one-year anniversary of the final phase-in date for the revised Hazard Communication standard (HCS), Title 29 Code of Federal Regulations (CFR) 1910.1200, has come and gone. This standard was revised by the Occupational Safety and Health Administration (OSHA). Employers were required to provide additional employee training for newly identified physical or health hazards as of June 1, 2016, and to update alternative workplace labelling and hazard communication programmes as necessary. This requirement was in effect until June 1, 2016.

Safety Data Sheets (SDSs) are documents that are written or printed around hazardous chemicals and are prepared in accordance with the requirements that are outlined in paragraph (g) of the HCS. These documents are an essential part of the written hazard communication programme that a company implements.

The Hazard Communication Standard is consistently included on the list of OSHA's Top Ten Most Frequently Cited Violations, and it was included on the list once again in Fiscal Year 2016. SDSs were referenced, either directly or indirectly, in all five of the most frequently cited sections under the HCS, which is evidence that they play an essential role in the system. During the 2016 fiscal year, the following five sections received the most readership:

Execution of the written hazard communication programme, which includes a detailed description of the employer's labelling, SDSs, and training components, as required by Section 29 CFR 1910.1200 (e)(1).

Employee training requirements, including chemical-specific information that must always be available through labels and SDSs, are outlined in Section 29 CFR 1910.1200, Paragraph (h)(1).

29 CFR1910.1200 (g)(8): Maintaining SDSs.

29 CFR1910.1200 (g)(1): Creating Safety Data Sheets

Details in the hazard communication employee training programme, including an explanation of labels and the SDSs, including how employees can obtain and use the information, as required by 29 CFR1910.1200 (h)(3) (iv).

It is easy to lose track of the current status of your hazard communication programme amidst the flurry of OSHA regulatory activity that occurred toward the end of President Obama's administration and continued into President Trump's first months in office. This activity continued into the new administration. Having said that, complacency has been the downfall of many otherwise effective hazard communication programmes. Maintaining compliance with regulations may require that some attention be redirected toward the SDSs maintained by your organisation.

This article was initially published in the issue of Occupational Health & Safety that came out in July of 2017.

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