Safety & Compliance: Step-by-Step Guide to Reviewing & Updating SDS
Missing, inaccurate and out of date SDS can cost you big time
HazCom citations continue to hover around the number two spot on the top released each year. If your SDS are missing, inaccurate or out of date, you can earn an OSHA citation with penalties that start at $14,502 per violation.
Not only is that a problem in and of itself, but SDS also contain the information required for creating GHS chemical labels. Inaccurate or out dated SDS can have a snowball effect causing citations for GHS labels as well.
Whether you’re using SDS to manually enter information for GHS labels, or using automated GHS label software and reviewing using SDS— there’s no question that accurate SDS are crucial for safety and compliance.
This article will walk you through how to set up a process of regular review and updates for SDS. We’ll also share SDS best practices and how to organize your SDS binder to provide better access for both workers and OSHA inspectors.
Step 1: Compile a list of chemical suppliers
Make a list of any suppliers that provide hazardous chemicals for your facility. This includes other items that may emit hazardous chemicals during regular use, such as industrial cleansers and bulk processing materials.
Step 2: Request a chemical list and SDS from each supplier
Ask each supplier for a list of any chemicals they’ve sent you in the last three years and current SDS for every chemical on the list. Create a checklist to keep track of the responses that you receive. Remember that it is the responsibility of chemical manufacturers and distributors to provide you with up-to-date SDS.
Step 3: Inventory the chemicals in your facility
Conduct a thorough review of your facility to inventory all existing chemicals. Ensure all necessary information is gathered by providing supervisors with a form to record each chemical along with its storage location, amount and use.
Ensure SDS hard copies are indexed for easy navigation and are protected. Durable SDS binder supplies keep SDS intact and legible for employee use and OSHA inspection.
Step 4: Index all current SDS in a master SDS binder
Sort your SDS alphabetically and assemble them in an SDS binder. If necessary, categorize safety data sheets by department/area. Even though your facility may require multiple SDS binders, designate one as the master copy to use as a reference when updating or creating all other SDS binders
Step 5: Use your master SDS binder to resolve discrepancies
Compare your master SDS binder with the SDS and chemical list you received from suppliers and the inventory of chemicals in your facility. Remove and/or archive old SDS for chemicals no longer used. Replace outdated SDS with updated ones received from suppliers.
Step 6: Make sure you have backup SDS
Part 1900.1200(g)(8) of the OSHA HazCom standard requires employers to keep a backup system for SDS in case of emergencies. The easiest way to do this is simply to create a backup SDS binder stored in a secondary location to your master SDS binder.
You can also use an external hard disk drive or optical disc, however, you must always have paper copies available to employees upon request.
Step 7: Distribute updated SDS binders for relevant departments
Employee accessibility is crucial for SDS compliance. Each department/area should have its own SDS binder. Once you have created an up-to-date master SDS binder, you can use it to create SDS binders tailored to each department and/or area in your facility.
If employees are exposed to hazardous chemicals while providing services in multiple locations (such as carpet cleaning, or pest control) you must also provide SDS binders for each vehicle so that each employee has access throughout the day.
Keep local backup copies specific to each department/area and a master SDS binder in one central location.
Step 8: Set up recurring SDS review
As you will discover, updating SDS is an ongoing process. However, it’s important to create a schedule for recurring SDS binder inspection and SDS review for your facility. It may be more work upfront, but it’s much less costly than earning an OSHA citation for SDS non-compliance.
In general, it’s considered best practice to review your SDS and GHS labels every one to three years. If you have a lot of new chemicals that come in and out of your facility, you may want to increase the schedule to biannually or even quarterly.
Choose a slow season for SDS review. Give your team plenty of time to assess which chemicals are active and which are no longer in use, which will make it easier to identify and resolve missing or misplaced SDS.
Older chemicals that are no longer used should be removed from active SDS binders and archived for reference to keep your binders streamlined.
How often should you update your SDS?
When new chemicals are brought into the facility, updated SDS should be added immediately. Diligently following this rule helps ingrain chemical safety compliance in company culture. Soon it will become routine for employees to continually update SDS binders and databases.
When new significant information about the hazards of a chemical (or new protection methods) becomes available, it must be added to the SDS within three months. This requirement is an OSHA-mandated SDS regulation to ensure the most accurate up-to-date information.
How to organize your SDS binder
Employees must have free access to SDS throughout the day. The best way to keep your SDS in order and readily accessible is to assemble them alphabetically in a dedicated SDS binder. An SDS binder should be highly visible and durable enough to protect SDS in heavy-duty environments.
A well-organized, complete SDS binder is divided into three sections: 1) the company hazard communication policy, 2) SDS and 3) relevant OSHA publications.
When you’re organizing your SDS binder, keep in mind that accessibility is at the core of SDS compliance. Dividers that separate the sections as well as A-Z dividers for alphabetizing SDS make an SDS binder easier for both workers and inspectors to navigate.
Company Hazard Communication Policy: This document should include the person responsible for maintaining the SDS binder and what is expected of them.
Relevant OSHA Documentation: Relevant information published by OSHA that is useful or beneficial for workers should be printed and included in your SDS binder. Specific OSHA requirements for safety data sheets published as an OSHA brief and new OSHA instruction directives such as CPL-02-02-079 are great examples of documentation beneficial for encouraging chemical safety and compliance.
More ways to increase safety and compliance with SDS
- Get a refresher on everything you need to know about SDS for safety and compliance
- Discover 4 quick SDS binder updates that make it easier for workers to stay informed
- Shop durable SDS binders and binder organization supplies engineered for heavy-duty workspaces
Please note, the contents of this article and related articles on avery.com/industrial are for informational purposes only, are general in nature, and are not intended to and should not be relied upon or construed as a legal opinion or legal advice regarding any specific issue or factual circumstance.