Since at least 1989, OSHA has allowed employers to use electronic SDS management systems to fulfill their HazCom obligations. This is great, since electronic systems are generally a lot more convenient and intuitive than a paper system. However, OSHA has identified a few potential weak points in electronic SDS systems. Keep these guidelines in mind to avoid falling out of compliance.
Train You Employees How to Use It
The whole point of SDS management is to make information available to your workers. If you haven’t taught anybody how to use the electronic SDS system, nobody is going to be able to find that information. OSHA doesn’t care if there’s technically a way for your employees to find an SDS; if they can’t figure out how to access it, you’re out of compliance. To avoid that mistake, make sure you’ve fully integrated the new system into your company’s HazCom plan.
Have a Backup Plan
Another potential issue with an electronic SDS management system is that it can be brought offline in the event of a power failure or hardware malfunction. In these situations, you should try to make SDSs available again as soon as possible. A good backup plan should be able to seamlessly take over in the event of a foreseeable emergency (i.e. equipment failure).
Here are some good precautions to take:
- Burn your SDS database onto a CD to prevent permanent data loss.
- Ensure that your electronic SDS management system (both servers and terminals) have access to emergency power.
- Implement a fax-on-demand system; many suppliers will fax you a new copy of an SDS on demand, which can be a useful backup if you electronic system is disrupted.
- Keep a non-digital master copy somewhere safe, to act as a backup.
Be Able to Produce a Hard Copy
Although electronic SDSs are allowed, under HazCom employees must be able to access a physical copy of any SDS. This doesn’t mean you have to keep binders of SDSs sitting around, it just means that you have to be able to produce a hard copy on demand. If you’re electronic system allows users to print documents, you shouldn’t have any trouble meeting this requirement.
As long as you keep those points in mind, an electronic system should drastically improve your HazCom program.
