Is electronic MSDS management OSHA compliant?
As you can guess, we get this question often. So let's clear the air once and for all. The answer, of course, is YES... as long as you meet these three criteria:
- Have a back-up system in place in case of a foreseeable emergency.
- Ensure that your system is integrated into your overall hazard communication plan.
- Ensure employees have hard-copy access if requested.
The fact of the matter is OSHA has allowed electronic access to MSDSs since 1989. According to an OSHA letter of interpretation dated October 3, 1989, an electronic MSDS management system is compliant as long as you have an adequate back-up system in place for emergency situations such as power outages, equipment failures, online access delays, etc.
The term "emergency" as it relates to back-up systems for MSDSs is further defined in the OSHA directive of 1998 called, "Inspection Procedures for the Hazard Communication Standard." Fortunately, it's not quite as long a read as the actual HazCom Standard (29 CFR 1910.1200). So, if you're at all unsure about what OSHA is looking for during an inspection, you'll want to make yourself familiar with this document.
Depending on your work environment, you may want to burn a few CDs or have a back-up master paper set on file and update it at least once a year. This way, in the event of an emergency, you can still make an MSDS "readily accessible" upon request. This is much easier to do if you are using an electronic system to manage the data.
Another viable back-up alternative is to use a fax on-demand system. Most MSDS vendors offer a fax-back solution. They are great as a back-up plan of for making MSDSs available to employees in the field or in places where you do not have Internet connectivity. We do not, however, recommend this as a stand-alone MSDS management system. On its own accord, a fax-system does not meet the OSHA compliance requirements in many workplace settings.
The OSHA Web site has some great tools to help you understand the regulations as they pertain to your specific industry and state. In case you haven't been to the site recently, they made some changes when the Obama administration took over. We think the navigation is definitely easier to follow, making access to information quicker and easier.
– The MSDSonline Compliance Team