Once you have your SDS authored, what is the next step? It might sound obvious, but you now have to manage your portfolio of SDS effectively in order to ensure compliance.
Processes vary greatly among workplaces. Perhaps you have a large team of dedicated SDS authors and dedicated staff for managing them. Or, perhaps your team is very small and you have resource constraints. Regardless, there are certain best practices that apply to all workplaces.
6 Best Practices for SDS Creation and Safety Data Sheet Management
1. You should understand and comply with jurisdictional regulations. This means having a robust system of tracking which chemicals are in your products and which jurisdictions you and your suppliers are located in.
2. You should request SDS from manufacturers/suppliers as soon as possible. Do not wait until the last minute to contact your suppliers. Understanding what your suppliers are doing, which chemicals they are using, and which SDS they have on premises will help identify gaps. For instance, if a supplier is missing a SDS, you are responsible for ensuring that the supplier authors or is provided an up-to-date SDS for chemicals that need them.
3. Ensure your SDS are systematically organized by department or hazard category for optimized hazard communication, as required under EHS and OSHA standards. In a digital world, it is best to have a centralized digital system in lieu of binders. Regardless, you should decide upon a logical system of organization. Should the SDS be arranged by department, jurisdiction, facility, or hazard category? The system is up to you; however, the goal is the same: your system should ensure quick access to SDS by employees who need to access them. Department heads, compliance leads, and individual employees working with chemicals should not need to spend hours searching for SDS.
4. Cross-check your chemical inventory. You should have workflows in place to ensure that each chemical used in your product has a corresponding SDS. Perhaps you can institute a regularly scheduled audit of your SDS. When new chemicals are added, or new mixtures are used, your team should ensure that SDS are added appropriately.
5. Train and educate employees on the “how-to” of SDS information. Providing SDS to employees is not enough. You need to train new employees working with hazardous chemicals to find SDS, how your SDS are organized, the purposes of SDS, and what the listed hazards mean for employee safety. New employee training can include SDS information. However, you may also want to regularly update existing employees – e.g., a refresher course – on SDS management. It is also wise to send alerts to employees when new SDS are added for new chemicals and mixtures, and when others are removed based on new chemical components and substitutions.
6. Regularly update SDS and replace outdated documents accordingly. Similarly to the previous suggestion, you should alert employees to SDS for new chemicals, but another step is to ensure your existing SDS are updated per regulations. You should have a system by which you replace outdated documents and replace them with the latest version. This requires version control, which is far easier in an electronic system than in a manual one.
How Regular SDS Updates Reduce Regulatory Risks
Keep in mind, there are many scenarios where an employee of yours would need an SDS:
- Chemical handling. Employees who handle chemicals need to understand the hazards involved (e.g., eye irritant) so that they know how to protect themselves with Personal Protective Equipment (PPE).
- Introduction of a new chemical. Employees may not be familiar with a new chemical used in the manufacturing of a product. Therefore, it is vital that employees have access to SDS that explain what the chemical is made up of and what the hazards are when working with it.
- Emergency situations. Even with the most stringent controls on chemicals, things can go wrong. If your facility has a chemical spill or exposure incident, then SDS must be accessed quickly. Emergency response is about timing. The sooner employees can pull relevant SDS, the safer they will be, and the more protected the environment and public communities will be.
- Training and educating employees on chemical safety in the workplace. Even if employees can access SDS quickly, they need to be capable of interpreting them to make the best use of them. Real-world examples help train employees, so they are prepared to work regularly with the chemicals and respond effectively in the event of spills and other emergencies. This also applies to situations where employees need to transport chemicals. Knowing how to handle transport safely is vital for the protection of employees.
- Risk assessments. SDS are valuable for conducting risk assessments among multiple facilities. The information contained in SDS can help determine the risk levels of using certain chemicals, and those risks can inform strategic choices regarding chemical substitutions.
Using Digital Tools for Better SDS Maintenance and Compliance
The above best practices can apply to both electronic and manual SDS management. However, using an electronic method, such as software, makes the process work for you and saves valuable time.
1. Binders can be lost or broken. With staff turnover, binders wear down. You could lose SDS pages, or SDS could contain mark-ups that make them hard to read. Electronic systems keep SDS in one place, in-tact, with version control. Notes and mark-ups can indeed be helpful, but electronic systems can provide that historical knowledge in a more legible fashion.
2. Dashboards are very helpful. Software allows different users to create customizable dashboards where they can view SDS in the way that works best for them. Customized settings are very helpful because employees can tailor software to fit their needs.
3. Integrated tracking. Keeping track of regulatory changes that impact SDS management is key. Software can help keep your SDS up-to-date by providing access to changing regulatory requirements, along with a place to manage SDS.
Learn more about 3E’s chemical compliance software and regulatory tracking solutions.
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