From: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>
Subject: Re: [DCHAS-L] Are SDS collections necessary (Was: Chemical Inventory Platform - On Site)
Date: Sun, 25 Nov 2018 15:57:01 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: CAEwQnqitfuT+5KmK-HwrXzo5gGr2Qh7TuHAndhx91wO2h-zCUA**At_Symbol_Here**
In-Reply-To <3B25DDD5-5ECD-4434-8421-F80CF014F265**At_Symbol_Here**>


We have a state MIOSHA program, under which our university is covered. In the last five years, we've had two audits and we've recently have been working with the Consultation, Training & Education (CET) arm of MIOSHA. They do courtesy audits where they tell us what to fix but don't issue citations.

The inspector/auditor can and will pick a random chemical off the shelf, look at a lab worker, and ask them to find the (M)SDS for the chemical. I've witnessed this happening.

We've been specifically told an on-line database is okay; an internet search is not. If using an on-line database, a backup plan needs to be in place if the internet is "down." Our current vendor provides a fax-back service. We are also considering providing regular backups on a thumb drive (or laptop) in our Public Safety and Police Services (PSPS) department.

A secondary advantage of an on-line database is, if you make it available to fire companies, it can go a long way towards meeting the university's obligation to the firefighters right to know regulations. Because our PSPS officers can access the database, that is our current arrangement of making it available. However, our vendor actually offers a login option for firefighters, should we choose to activate it.

We provide training on accessing our vendor as an "add-on" to our online hazard communication training as well as links to this training on our web pages. The SDS link is on every University web page. And, we've started requiring both the web address and a QR code on every lab door entrance. We have specifically told labs that they can't post "search the vendor's website" as an alternative to our vendor. We don't discourage paper copies of SDSs in the lab, but we expect every lab worker to know how to access the vendor (because the web portal is behind a university login, we allow students, as well as employees, to access the link).


On Fri, Nov 23, 2018 at 4:44 PM Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**> wrote:
> >A provocative question with many facets. Always good to stir the pot!
I should have specified that I was thinking of the laboratory use case with inventories of more than 50 chemicals in laboratory scale containers when I posed the question. I also don't think of regulatory compliance as value added to the use of the chemical, but rather an adjunct to the use of the chemical. Given that the average penalty associated with a HazCom violation is $500, which is less than the cost of many chemicals, I'm looking for ways that the safety information can be best used to support better use of the chemical.

> >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.
I'm not sure that SDS's are for employees - they are written by chemical safety experts and significant safety expertise is needed to parse and interpret the information on the SDS. My hope is to help lab workers understand the GHS labels proficiently and then work with them to use SDSs to help answer specific questions that they have after reviewing the label information.

> > 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.
There are many other barriers associated with an Internet search - cryptic search ranking mechanisms obscure valuable sites, web sites that hide information behind poorly named tabs, etc. However, I'm not sure acquisition of an SDS is the end goal of someone working with a chemical - I suspect that they want to be able to answer a question about the use of a chemical.

> >Might find a web page that says sodium chloride is a probably carcinogen because chlorine is found in carbon tetrachloride etc.
This is precisely why a significant amount of chemical safety expertise is need to use SDS's; I think that many safety people undersell their skills in dealing with these challenges when they suggest anyone working with a specific chemical should be able to deal with all of the safety information available for it.

> > 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.

I agree that many emergency responders ask for SDS's, but I don't think SDS are well suited as emergency planning documents.

As you said, since (M)SDS's have been around for 30+ years and the GHS for 5 years, I think it's time to consider whether their value are worth the investment or whether there are other approaches to supporting worker's right to know, right to understand and right to act.

Thanks to everyone for their comments on this. I'd be interested in what others think as well.

- Ralph

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


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Jeff Lewin
Chemical Safety Officer
Compliance, Integrity, and Safety
Environmental Health and Safety
Michigan Technological University
Houghton, MI 49931

O 906-487.3153
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