From: Michael <mabuczynski**At_Symbol_Here**HOTMAIL.COM>
Subject: Re: [DCHAS-L] Are SDS collections necessary (Was: Chemical Inventory Platform - On Site)
Date: Fri, 23 Nov 2018 15:52:16 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: BY2PR18MB03097E4BE73C4DE0F8B4A619ABD40**At_Symbol_Here**

As a former OSHA Officer there are several points here
1 you must have a chemical inventory along with. SDS for each on site. Can be digital. Sometimes a SDS service helps you
2 employees must have access during their shift. They need to know how to get them (training)
3 any new chemical received is not supposed to be opened /put in use until training is conducted prior to use. This included the review of the SDS

Mike Buczynski 
Global Manager Hazard Communication and Product Stewardship
Johnson Controls International 

On Nov 23, 2018, at 8:36 AM, ILPI Support <support**At_Symbol_Here**ILPI.COM> wrote:

A provocative question with many facets. Always good to stir the pot!

Requiring employees to do an Internet search in an emergency is a citable violation of the HazCom Standard. See my SDS FAQ question on that here: 

Further, SDS's are part of your training requirement (see the next FAQ answer in that link). Hard to train employees with information you don't have in hand and that they can't refer to.

It comes down to the "ready access" requirement:  Note that while electronic access (with a database, for example) is permissible (see FAQ again), that assumes the information is readily found by a trained employee who knows how to use the system.  An Internet search, on the other hand, presents a barrier for several reasons - for example, if a manufacturer has gone out of business, it's an esoteric or proprietary chemical etc. not to mention that many folks really don't know how to search effectively.

In fact, most employers are small businesses, so a mechanic in a garage probably knows diddly about how to find that info on the Internet and assess whether PubChem or anyone else is an authoritative source. Might find a web page that says sodium chloride is a probably carcinogen because chlorine is found in carbon tetrachloride etc.

Also note that while PubChem might have GHS data on specific chemicals, such data alone is not sufficient to meet the HazCom standard.  A complete SDS has the manufacturer's name and contact information along with other data that might be critical to, say, an emergency room physician. See  I should update that entry to include PubChem, thanks.

Finally, an OSHA inspector can ask an employee to find the SDS for a chemical they are working with during an inspection to ensure that the communication requirements have been satisfactorily met. Not sure a lot of people would be able to do that at their workstation on a tiny phone with a weak signal under that kind of pressure.

Rob Toreki

Safety Emporium - Lab & Safety Supplies featuring brand names
you know and trust.  Visit us at
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Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012

On Nov 23, 2018, at 7:40 AM, Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU> wrote:

Does anyone on the list use "Environmental Health and Safety Assistant" by On Site Systems, particularly with respect to chemical inventories and SDSs?

I wonder what the added value of such a service is relative to using manufacturer's web sites on the Internet to find SDS's or PubChem to find GHS information on specific chemicals? With GHS now available, I'm not sure that institution-specific SDS collections are worth the administrative overhead they present.

Thanks for any thoughts on this.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859


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