From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Subject: Re: [DCHAS-L] SDS criteria in a Non-OSHA state
Date: Tue, 4 Sep 2018 19:38:59 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: A2961B8E-BAD8-47DE-BB32-DCF903608E22**At_Symbol_Here**

I have summaries of the "ready access" requirement and electronic access here: 

As you can see, a web link alone is NOT acceptable, because you can not guarantee Internet connectivity in an emergency situation. There needs to be a backup.

OSHA constitutes minimum best practices, so no, it really is not up for interpretation because you would presumably be hit over the head with it in litigation if you didn't follow it.

Rob Toreki

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On Sep 4, 2018, at 6:44 PM, Tammy M. Lutz-Rechtin <tlutzrec**At_Symbol_Here**UARK.EDU> wrote:

There may already be a thread on this particular topic. If so, please refer me to it.
The entire issue of what access to safety data sheets means is in current debate among some at my institution.  We are a "non-OSHA" state but do have a "Right to Know" Act. Our chemical hygiene plan states that one must " Maintain accurate and timely Safety Data Sheets (SDS's) readily available in the Laboratory to communicate the hazards of hazardous chemical products." Some people have taken this to mean that a web link is all they need instead of a printed copy of the SDS or a copy on an electronic database. 
It is best practice, to have immediate access to an SDS in case of emergency. On-site paper copy is best, followed by an electronic version accessible on-site with an off-site backup for either. Given the we are not an OSHA state, is immediate access up for interpretation?  The employee should be able to request a copy of the SDS, but can someone then do a google search first before handing the requester a copy?  My common sense say "no" but what do I have besides OSHA to argue against this approach. I suspect the "Right to Know" Act, but it does not clearly define immediate access.
Tammy Rechtin
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