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|Title: 02/18/1999 - Clarification of systems for electronic access to MSDSs.|
|Record Type: Interpretation||Standard Number: 1910.1200(g); 1926.59(g)|
February 18, 1999
The Honorable Ron Wyden
United States Senate
Washington, DC 20510
Dear Senator Wyden:
Thank you for your letter dated December 14, 1998, addressed to the Honorable Alexis Herman, Secretary of the U.S. Department of Labor, in which you requested clarification regarding systems of electronic access to Material Safety Data Sheets (MSDSs). Your letter has been forwarded to the Occupational Safety and Health Administration (OSHA) for a response. Below we have provided a brief history regarding the issue of electronic access. Following this, we have provided answers to your four questions.
OSHA has allowed electronic access to MSDSs since at least July, 1989. Our most recent interpretation (written on October 13, 1998, to Mr. Mark Hoffman, Rudolph/Libbe, Inc., Walbridge, Ohio) expanded the use of telephone transmittal of hazard information in "emergency" situations. The term "emergency," as it relates to back-up systems for electronic access is discussed in our compliance directive, CPL 2-2.38D (Inspection Procedures for the Hazard Communication Standard, dated March 20, 1998). In this context, "emergency" is defined as foreseeable failures in the electronic system such as power outages, equipment failures, on-line access delays, etc., and is not meant to encompass catastrophic events, medical emergencies, or other situations.|
Previous to the October 13 letter to Mr. Hoffman, the only time telephone transmittal of hazard information was permitted was under the mobile worksite provision of the rule. The mobile worksite provision allows employees who travel between worksites during the work shift to phone-in for hazard information. In this situation, the employees have access to the MSDSs prior to leaving the worksite and upon returning. The telephone system, therefore, is seen as an emergency arrangement.
400,000 MSDS's in your shirt pocket...
With that background, we have paraphrased your questions and provided answers below:
Emergency lighting from Safety Emporium keeps you safe in an power failure.
Photoluminescent signs, wayfinding tapes and stair treads are also available at Safety Emporium.
Safety posters are a terrific way of reminding employees of proper procedure. Get yours at Safety Emporium.
If we may provide further information or assistance, please do not hesitate to contact OSHA's Office of Health Compliance Assistance on 202-693-2190.
Charles N. Jeffress
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=23426&p_text_version=FALSE