OSHA Record Keeping
Sending and Receiving Safety Data Sheets

There are lots of songs out in the world about letters. You remember those things we used to write and send in the mail and have now been replaced by emails? There are some truly classic song regarding letters and the messages they carry. In 1961 The Marvelettes were begging their postman for a letter from a boyfriend indicating he was coming home. Click here for their song. This was followed in 1967 by The Box Tops song “The Letter” (listen here) where the singer is going home “because my baby done wrote me a letter”. This was followed in 1970 by Steve Wonder’s “Signed, Sealed, Delivered” that you can hear here. In this song the “letter” is actually Stevie letting his love know he is still hers.

So how do letters fit in today’s world of hazard communication? You may think they don’t, but actually they do. Think about when and how you receive your Safety Data Sheets (SDS). There are requirements for ensuring all workers know the hazards of the materials with which that work and that is usually accomplished by the SDS. What are the requirements for ensuring that you have an SDS for the hazardous chemicals in your workplace?

First, we will look at what the United States’ OSHA HazCom 2012 says:

“Employers shall maintain copies of any safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals, shall obtain a safety data sheet as soon as possible for sealed containers of hazardous chemicals received without a safety data sheet if an employee requests the safety data sheet, and shall ensure that the safety data sheets are readily accessible during each work shift to employees when they are in their work area”

The Canada Labor Code states the following about Safety Data Sheets:

“125.1 … every employer shall…

(e) … make available to every employee, …, a safety data sheet for each hazardous product to which the employee may be exposed that meets the requirements set out in the regulations made under subsection 15(1) of the Hazardous Products Act

And the Canada Occupational Health and Safety Regulations say:

10.32 (1) Where a controlled product, … …, is received in the work place by an employer, the employer shall, without delay, obtain from the supplier of the controlled product a supplier material safety data sheet in respect of the controlled product”

Given all of these regulations, what does this mean to you? What is the best way for you to get and/or give a Safety Data Sheet?

The Canadian Workplace Hazardous Materials Bureau recently provided the following clarification:

“A bilingual SDS must be provided to the purchaser of the hazardous product, either in hard copy (e.g. mail, hand delivered etc.) or by electronic means.

The following are examples of ways in which a bilingual SDS could be provided to a purchaser by electronic means:

  1. The supplier could send an email to the purchaser and attach the SDS to the email (in the case where the English and French portions of the SDS are two separate parts, both the English and French parts must be attached in the same email).
  2. The supplier could provide the purchaser with a universal serial bus (USB) stick or a compact disc (CD) on which the SDS has been saved (in the case where the English and French portions of the SDS are two separate parts, both the English and French parts must be saved on the same USB stick or CD).

It is important to note that it is not acceptable to provide an SDS by only providing the purchaser of the hazardous product with a website address or hyperlink from which the purchaser may download the SDS for the product that he purchased.”

For the United States, as part of the OSHA HazCom2012 Regulation it states:

(g)(8) The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (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.)

(g)(10) Safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in their work area(s).

If you are new to a business, have a new product line, have switched roles always be sure you know where to find the SDS. ICC The Compliance Center offers various safety data sheet services, including creation and hosting. Contact us for more information on how we can help. Let’s hope your SDS is never lost in the mail.

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