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.    

 

Regards,

 

Brandon Chance | AVP, Chief Risk and Safety Officer

Division of Risk and Safety|Kansas State University

214 Anderson Hall|919 Mid-Campus Dr.|Manhattan, KS 66502

O: 785.532.6261|M: 469.978.8664|Email: brandonchance**At_Symbol_Here**ksu.edu

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> on behalf of "Rakers, Rose" <rrakers**At_Symbol_Here**BEN.EDU>
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Date: Thursday, November 2, 2023 at 6:03 PM
To: "DCHAS-L**At_Symbol_Here**Princeton.EDU" <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Subject: [DCHAS-L] SDS system

 

This email originated from outside of K-State.

 

Could you please let me know what system you use for maintaining your SDS’s? We are looking at getting rid of our electronic system and going back to a strictly paper system for cost reasons. I do have 2 file cabinets (just for the science building, one locked for the fire department and one open for anyone else) with paper copies of the SDS’s in addition to our electronic system. My concern is the requirement that the SDS’s be up to date. Our electronic system takes care of that part of it for me, I’m worried that trying to maintain that myself is going to take much more time and effort than I have available.

 

Yes, I understand that in all actuality people are just going to google the first SDS for that chemical that they can come up with on their phones. But, my understanding is that we are required to have them available here on campus as well (whether in an electronic system or physical system). They need to be readily available, up to date, and kept for 30 years after the chemical is no longer here.

 

Do you use an outside company to help with this? If yes, which one? Any pros/cons?

 

Do you keep printed copies of the SDS’s in each lab? (Related to that, if I have one file cabinet on the floor with all the SDS’s do you think that qualifies as readily available?)

 

Any other comments/suggestions?
Thank you!
Rose

 

 

Rose Rakers, Ph.D.

Chemical Hygiene Officer

Assistant Professor

Department of Physical Science

College of Science and Health

 

Schedule office hour appointments at: https://outlook.office365.com/owa/calendar/OfficeHoursRakers**At_Symbol_Here**ben.edu/bookings/

 

o: 630-829-6571

Benedictine University 5700 College Road Lisle, IL 60532 ben.edu

 

 

 

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org