Meet OSHA Standards: The Only SDS Compliance Checklist You Need
- A compliant HazCom Program needs to have current and complete SDSs that your workforce can access immediately, as well as correct labeling
- You need to choose a system for ensuring that your team can easily access not only the SDS data, but also labels, training, and other relevant data
- Systems like KHA Online-SDS can help you comply with OSHA’s standards with their chemical inventory systems and standardized SDS indexing
As OSHA rules continue to change, meeting their standards becomes more challenging. At the same time, delaying means that you potentially face drastic penalties. The 2024 Hazard Communication Standard (HazCom) has been the center of this issue, with its final ruling only appearing recently, but fortunately, there are solutions available.
Read on to learn the basics of SDS compliance and how to utilize tools from companies like KHA to ensure your team has access to a current and powerful safety documentation tool. Use this workplace safety checklist to discover how to avoid OSHA’s penalties today.
What Does SDS Mean?
A Safety Data Sheet (SDS) is a method of communicating hazards and protective measures against them. They contain summaries of the various hazardous chemicals that a company may handle through manufacturing or distribution.
Manufacturers create and update these, passing them on to each chain as the chemicals change hands.
What Is SDS Compliance?
SDS OSHA compliance means ensuring that your SDS library covers every one of these, as well as any by-products created during everyday work that meet these criteria.
You also need to ensure that the people responsible for looking after and updating these are clearly named and recorded. Having one person per task is also critical, which includes:
- Inventory
- Labeling
- Updating SDS documents
- Training
These people should also have a backup in case any of them are unable to continue in their role at any time.
Does OSHA Require an SDS?
While standard exceptions exist, in general, you should expect that, unless you know otherwise, every hazardous chemical requires an SDS.
Electronic and paper formats are both presently acceptable, especially as a backup for one another. However, so long as workers can immediately access them, they are fulfilling the requirements.
What Are the Five Requirements Included in the SDS?
All SDS must include the following data to be considered up-to-date. However, the EPA and OSHA offer a more robust list of the information you need to include.
Sixteen-section format: The SDS must follow OSHA’s list of sixteen sections that detail the nature of a chemical. These are consistent with the information that GHS holds itself to.
Accurate identification details and supplier information: These should clarify the nature of a material, including:
- What it is or its identification
- Recommended uses for the chemical
- Restrictions on its use
- Manufacturer or importer contact details
Hazard classifications and labels: These use signal words, pictograms, and other statements to ensure that what the chemicals are and do is clear.
Composition and exposure data: The ingredients contained in the chemical should appear here. In the case of trade secrets, it should provide a potential range of chemical compositions.
Exposure limits and toxicology information for the chemical should also appear here.
Handling, storage, and emergency information: This data should include:
- How to move or store the chemical
- How to avoid exposure
- What PPE to use
- First aid on exposure
- Firefighting steps
- How to respond to spills
Labeling and Access Requirements
Make sure to include the relevant data on every shipping label and workplace label to convey any hazard information, keeping it consistent with what you will find on an SDS. In addition, work with your workforce to ensure that you provide employee training to all individuals whenever a new chemical hazard might be in the area. Finally, ensuring SDS access for all can mean that everyone can find this information without any delay.
Make sure that this information is both available and up to date at all times. In many cases, using a centralized database can help to ensure you only have a single source of truth for these documents.
Frequently Asked Questions
What timelines apply to SDS updates after formulation changes?
For any substances that you handle, make sure to update any labels and SDSs within eighteen months of July 19, 2024. For mixtures, this number increases to 36 months.
Make sure that you also renew your workplace programs and training by July 20, 2027, and January 19, 2028, respectively, to follow OSHA regulations.
After this, ensure that you audit every element of your safety operation regularly and that you can see which you have not updated. You need to revise SDSs within three months and labels within six months, for example, whenever new information is available. Keep proof of this for audits, documenting updates and any supplier correspondence as they occur.
What counts as readily accessible when using a cloud system?
Workers should be able to access safety documentation, such as SDSs, immediately. They should never be forced to find a supervisor, as they may need the data in their immediate vicinity to prevent harm coming to others.
Access should work at any time, whether between shifts or when an individual is out of the workplace, in case they need to provide expert opinions remotely. Alternatively, an Internet or electricity outage may require them to access the data on a mobile device without an internet connection, and so SDSs should be downloadable.
How can we reconcile OSHA requirements with GHS guidance in practice?
Make sure that you understand the difference between the two concepts. The Globally Harmonized System (GHS) is a United Nations model for how safety data should be formatted. Whereas the Hazard Communication Standard (HCS), which OSHA uses, is an enforceable law.
As such, follow the HCS as a priority when they differ.
Ensuring SDS Compliance With KHA
With a clear checklist of what to do and when to do it, you should now be able to ensure SDS compliance. However, it can often be challenging to do this across your whole company.
We provide a software system that helps you comply with all OSHA requirements related to SDS documentation, including mobile access, offline backups, and HazMat inventorying.
To ensure that you set up this system correctly, contact KHA Management Consultants. We can provide SDS management support tailored to the exact nature of your company and ensure that you remain compliant.