Did you know that improper hazard communication is commonly in the top ten list of OSHA violations? On January 16, 2021, the Occupational Safety and Health Administration (OSHA) increased its fines.
Now “serious, other-than-serious and posting requirements” costs up to $13,653 per violation. For each day that a company fails to correct a violation, they’re charged $13,652. In the event that a business refuses to correct or repeats a violation, it costs $136,532.
This demonstrates the importance of avoiding SDS management mistakes. Keep reading to learn about common mistakes related to SDS and how to avoid them.
The Top SDS Management Mistakes
Failure to comply compromises employee safety and risks significant monetary penalties. Use this guide as a learning tool so you won’t make the same mistakes.
1. Not Following OSHA Standards for Employee Training
OSHA mandates training for all staff when they start working with hazardous materials. This training must not be delayed and should include:
- How to read and use a Safety Data Sheet (SDS)
- An explanation of the business’ hazard communication program HazCom
- Potential adverse health risks associated with exposure
- Proper work practices and precautions to prevent harm
- Proper use of personal protective equipment (PPE)
- Explain hazard categories such as irritant, corrosive, carcinogen, etc.
- Hazard symbols
- Labeling requirements
- Emergency procedures in the event of an exposure
- The employee’s specific duties during an exposure event
- A presentation style in the employee’s language that facilitates learning
It’s not appropriate to simply tell employees to read the SDSs. Training may involve live instruction, audiovisuals, or interactive virtual formats. Employees must have the chance to ask questions to clarify and ensure understanding.
Training covers categories of hazards such as sensitizers, carcinogens, or acutely toxic agents. You don’t need to teach about each separate hazard.
Employees must have further training when new health or physical hazards enter their area. If you add a new chemical that’s similar to others in use, the staff should know the precautions. Unless the employees need to know about new hazards or protocols, they don’t need further education.
2. Not Providing Easy Access to MSDS
The OSHA standard mandates that at-risk employees have open access to SDSs. This may be via hard copies or online software systems. With computerized programs, ensure the staff knows how and has logins to access this data.
If you use an online system, make sure you have a backup plan in case of power outages. Assign one or more staff members to obtain and maintain the SDSs. If you use a vendor solution, these staff members should ensure that it’s functioning.
3. Not Having an SDS Management Strategy
Manufacturers of hazardous materials have the responsibility to create and provide SDSs.
Manufacturers and imports are also tasked with providing updated SDSs when changes occur. OSHA gives them three months to generate the updates. They have six months to have products fully labeled.
Yet, OSHA still holds businesses responsible for creating and maintaining a HazCom program. This includes managing data sheets for all hazardous materials. It’s your responsibility to ensure that you have the most current version of all SDSs.
4. Not Having a Written HAZCOM Plan
The most common violation is, in fact, not having a written HazCom plan. This is often the first thing an OSHA inspector asks to see. This plan must include the following types of data:
- A list of employees assigned specific HazCom duties such as:
- Obtaining and maintaining SDSs
- Educating employees about SDSs and the HazCom Plan
- Maintaining proper labeling
- Description of your labeling system
- Explanation of how employees receive HazCom training
- Description of when new employees or those with new exposure risks receive training
- Description of how employee access to SDSs is maintained
- Protocols for non-routine task hazards
- Protocols for hazards related to chemicals kept in unlabeled pipes in the workplace
- A comprehensive list of all workplace hazardous chemicals
Today, many businesses use HazCom/SDS software solutions to meet these standards. This ensures that you’re compliant and allows you to focus more time on your business.
5. Improper Labeling of Hazardous Materials
To meet OSHA standards, every hazardous chemical must have a proper label, tag, or marking. Pipes, piping systems, and moveable containers for immediate use are exempt.
Labels must be legible, displayed prominently on the container, and in English. Also, the labels may also contain information in other languages if needed.
Acceptable labels include those that shipped with the chemical or a product identifier. It must have a combination of words, symbols, and/or pictures. They should give information about the health and physical hazards of the chemical.
It’s key to know that an SDS can’t substitute as a chemical label.
6. Believing SDSs Are Only Needed to Meet Regulations
Many individuals believe that the only reason for SDSs is to “check the box” for OSHA standards. In fact, SDSs include lifesaving information for those using or transporting the material.
Section eight details the protective measures and PPE needed when using the chemical. Section fourteen describes precautions to take during transportation.
SDSs also describe the specific action needed if an exposure occurs. This is why it’s so important for everyone to have immediate access to the SDS.
Are You Looking for a Quality SDS Management Company?
This article provided information to help you avoid SDS management mistakes. Online-SDS™ is proud to have created the first computerized SDS management system. We now provide a complete suite of compliance management solutions.
You won’t have any initial startup costs to start managing SDSs online. We provide multi-level programs, personalized service, and simple monthly invoicing. You’ll also have access to operator assistance 24/7/365.
Contact us today to learn how our services can help your business.