A common dilemma that many employers face is not if an electronic Safety Data Sheet (SDS) management system is for them, but rather, what does OSHA require if they use one. OSHA says “electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options”.
OSHA accepts many methods for managing SDS, as long as these five guidelines and the Hazard Communication Standards are followed.
- Employees must be trained on how to access to the data retrieval devices, including the specific software involved.
- An adequate back-up system for rapid access to hazard information must be provided in the event of an emergency including power outages, equipment failure, or delays in, or loss of, on-line access, etc.
- The electronic SDS management/retrieval system must be integrated into the overall written Hazard Communication Program including procedures on how to retrieve SDSs electronically.
- In case of emergency, hard copies must be available on demand so that they can be provided to employees and medical personnel as needed or requested.
- If the SDSs are stored at the primary workplace, the employer must ensure there is no delay in a worker receiving a requested SDS while at any mobile, remote or temporary worksite.
Some guidance on maintaining SDS can be found on page 21 of the Small Entity Compliance Guide through this link: https://www.osha.gov/Publications/OSHA3695.pdf.