MSDS Records - Is a hard copy required if I have a scanned copy?

[Helmut Jilling]

How important is it to have immediate access in case of an emergency?

Stijloor.

This response is to this one by Stijloor, and the posts by Doug Tropf and Randy.

I have suggested for years that companies consider putting their MSDS sheets on their server and permit electronic access throughout the plant. They can be protected by making them read only or PDF files. I find many companies are now doing this.

I encourage that any significant or critical ones should be copied and posted at the point of use. Few MSDS' are critical, but if they are, they should be right there. You don't want to take time to go fetch it, whether by paper or electronic.

In the US, the OSHA website only stated they had to be "accessible." More recently, I believe the website actually clarifies that electronic access is acceptable.

As to using a service only, I would be concerned whether anyone is actually reviewing them or are they just filing them?

 

[Dr. L. Ramakrishnan]

Re: MSDS Records

Dear Samsung,

I appreciate your concern.

Your post clearly brings out the differene between a paper EMS and an effective EMS (by effective I mean "serving the intended purpose"). If the issues identified in the earlier post have not been addressed in the MSDS one has received from any source, an effective EMS would require that these information are obtained and added to the MSDS used in the organization. Unless this information is included in the MSDS, the document is of no use for the intended purpose; as a management system EMS requires that we are prepared for any accident/incident/emergency while dealing with a chemical substance; that can be done only when the required information is collected, reviewed and incorporated in documents meant for the purpose, like in this case MSDS.

One more point that I missed in my earlier post is that MSDS also gives you the composition of the material; now a days this information is very useful for dealing with EU directives like RoHS, REACH etc. For some organizations, therefore, MSDS will be requied under 4.3.2 of ISO-14001 for this purpose too.

Please don't mistake me; my purpose of sharing the above with you is just to give you the other point for pondering, without rejecting your view.

With kind regards,

Ramakrishnan

 

[samsung]

Re: MSDS Records

Hellow Dr. Ramakrishnan,

Thanks for your response.

I didn't mean that the information required for effective operation of an EMS, if not available in the MSDS or any other document, shouldn't be gathered and incorporated into the system. One should not give up unless one is equipped with all necessary information and knowledge for smooth operation of the EMS.

What I wanted to convey is that the amount of information used to formulate effective (environmental) emergency procedures is often not available in the MSDS. The best resources for such information are none other than the statute (rules, regulations, guidelines), regulatory websites, text books, standards, scientific journals, abstracts etc.

Just to quote an example, I had to devote serious efforts to find out what to do if a mercury thermometer or a CFL breaks. The required information wasn't available in any of the MSDS nor in the Merck Index. Finally I got very good guidelines at the US EPA website. Similarly, I referred to HSE, OSHA and various IS Codes while documenting the procedure for safe disposal of material containing asbestos. Likewise CPCB guidelines are referred to while disposing petroleum/rubber/plastic residues in case such materials are incidentally set to fire. These are just few of the examples to highlight how the information was or could be collected to manage the task.

Ofcourse, MSDS provide some information on the material characteristics and in certain cases its ecological effects based on which further detailed information needs to be collected from other sources for reference or to formulate the required documents. In short, an MSDS as such can't help to mitigate any emergency.

 

[PotentCompoundSafety]

MSDS can be electronic without a scanned backup, but there cannot be any barriers to access. See the OSHA letter of interpretation on this issue by searching "msds electronic access" on the OSHA web site. Make sure that all your employees know how to access a MSDS quickly and that you have some sort of plan if there is an emergency situation or power failure.

 

[Randy]

How important is it to have immediate access in case of an emergency?

Stijloor.

Depending upon the location, the emergency and the results....Prison!