The OSHA requirements of (M)SDS availability are not changing. You can make them available on line, as long as there are no impediments to access. For example, no individual who ought to have access should have to go to a supervisor's office or seek help or permission from another to get on line and review one. (This is paraphrasing an OSHA representative presenting on the Hazcom 2012 implementation this week at the AIHce in Montreal.) In addition, you must have some sort of backup function to provide immediate access to (M)SDS in the event of a power failure, etc., when access is needed.
On the issue of whether it would be acceptable to make available an Aldrich (M)SDS on sodium hydroxide when your NaOH is from Fisher, my less authoritative response is that my impression of the HazCom 2012 changes would make that UNacceptable. But others may read it differently.
I am in the process of deciding whether to recommend that my college pay to subscribe to an (M)SDS service (ChemWatch) or download and store my own repository of (M)SDS pdf's. I'd be grateful for your thoughts about the proper way to manage access to (M)SDS by employers.
- Do we have to have paper copies storied in a physical shelf location, or is a site license to ChemWatch OK. Can I simply maintain an easily accessible link to a folder of downloaded pdf's on our server?
- If I have a bottle of sodium hydroxide from Fisher and a downloaded (M)SDS for NaOH from Aldrich, does that meet the OSHA requirement?
- Are others using ChemWatch, and is it a good system (worth the money)?
- Are there other considerations I should be aware of as I weigh the $2000 yearly fee against the tedium of maintaining the system myself?
Thanks for your thoughts!
Kyle Strode
