DCHAS,

This opinion may raise some eyebrows or be rather unpopular, but this is something I struggled with for many years as a lab manager, then an EHS professional.  I wanted to walk the list-serv through my thinking at a previous organization. 

1. When I arrived at the organization, it had a membership to an online database that cost in excess of $2500 a year.  It was not maintained and was not ever updated.  I checked analytics after a year and I was really the only person that had even attempted to access it.  
2. OSHA uses language such as “readily accessible”.   In this day and age, readily accessible could be interpreted as by computer or smartphone.   As all of us know, trying to maintain paper copies in a synthetic lab with 2500 chemicals is next to impossible, and I would readily expect a research laboratory to have access to the internet via computers and for members to have smartphones, so I took the following initial approach to areas that I considered to be under the Laboratory Standard (more on this later).
1. Built a website with links to all of the common chemical manufacturer SDS search pages and added that information to mandatory laboratory and chemical hygiene training.
2. Added to lab inspections questions to verify both wifi and cellular service within labs – this covers the aspect of redundancy to access an SDS and all hazardous labs were audited annually.
3. Based on this, and the general knowledge that most people Google it anyways, and in talking with a few outside consultant friends – depending on the inspector, this may have been a defensible position if we were ever audited by OSHA.  I also took into account cost of maintaining a system that was never used, versus potential OSHA administrative fines.  
4. More recently, that institution implemented a chemical inventory system institution-wide that provides links to common manufacturer SDS links as part of the inventory system.   So each chemical I nthe inventory has a safety information link. It took about 7 years for us to get to this point.
3. Note that the above only applied to areas that we considered to be under the Laboratory Standard.  In areas that fell under HazCom-think trade shops in Facilities- where inventories were much more limited or areas where there may not be a reasonable expectation of access to both a smartphone and a computer, we still kept paper binders at prominent locations within those locations.

Just my two cents.    

This email originated from outside of K-State.