Rudimentary forms of material safety data sheets (MSDSs) have been available since the 19th century. Some experts trace their history even further back to hieroglyphics found inside the Egyptian pyramids regarding the effects of various chemicals. But the modern MSDS is a relatively recent invention, appearing a little over 50 years ago, with the first regulatory requirements adopted by the former Bureau of Labor Standards for the maritime industry, some 20 years before OSHA was created.

Today, OSHA's Hazard Communication Standard (29 CFR 1910.1200) regulates the use of MSDSs. The standard requires you to obtain copies with incoming shipments of hazardous chemicals, to ensure that MSDSs are readily accessible to employees during each work shift, and to make sure workers understand the safety and health information contained in this indispensable document, which OSHA calls a "one-stop resource for everything you might need or want to know about a chemical."

Complete, Accurate, and Clear

Since MSDSs are really the backbone of the Hazard Communication Standard and your hazard communication program, it's important to make sure they're complete, accurate, and clear. To that end, you should:

• Audit the MSDSs used by your employees to be sure they are complete and comply with OSHA requirements. Remember, required information includes:
• Material identification
• Identity of hazardous ingredients
• Physical/chemical characteristics
• Fire, explosion, and reactivity hazard
• Health hazards and first aid
• Precautions for safe handling and use
• Control measures
• Double-check with your safety director or the chemical manufacturer if you have questions about information contained in an MSDS. The standard says that the manufacturer or importer who prepares the MSDS must "ensure that the information recorded accurately reflects the scientific evidence used in making the hazard determination."
• Review sheets in your inventory and "translate" technical jargon that makes the MSDS difficult for users of all educational levels to understand, or ask that the manufacturer or a specialty safety consultant do this for you.
• Consider the needs of employees who don't read or understand English. Although OSHA only requires that MSDSs be in English, the law also says you must ensure that workers know how to obtain and use information on MSDSs and chemical labels. One solution is to have bilingual employees on each shift who can translate relevant MSDS data. Better still-especially if you have a lot of non-English-speaking employees-have your inventory of MSDSs translated. If you opt for the second solution, be sure to choose a translator or service that specializes in technical safety information.

Access Is Essential

In addition to content, you also have to be concerned about access. Employees must always be able to get their hands on the MSDSs they need. This means that whatever MSDS management system you use-paper or electronic-it must be functional and available at all times.

If you maintain a paper file, make sure it's easily accessible and that employees know where to find it.

If you use an electronic system, OSHA says you must make sure there are "no barriers to immediate employee access." For example, if your MSDSs are on CD-ROM or your company's intranet, failure to provide computers and/or computer training to employees would be considered a barrier to access and, therefore, subject to citation by OSHA. Similarly, if you use a fax service to provide MSDSs, failure to provide immediate employee access to a fax machine or to train employees how to contact the service would be a violation of the standard.

Another important issue: If you normally rely on an electronic system, anticipate emergency situations, and make sure you have a backup system, such as a paper file, to ensure access in case the electronic system fails.

Time for Review

Of course, providing MSDSs is only half the story. The other half is that your employees actually have to use them. One way to help instill the habit of actively using MSDSs is to hold refresher training on the different hazardous chemicals employees work with-and to make the MSDS for each chemical the centerpiece of the training session. There are plenty of reasons to justify such a session:

• A new chemical is introduced into the workplace (or a familiar chemical from a different manufacturer).
• A new use or process for a chemical is introduced, requiring new or different safe work procedures.
• A new MSDS form-either a different format, or revised information-comes into the workplace.
• New employees entering the workforce may not be familiar with a chemical and safety rules for using it.

Advice from an Expert

Perhaps the best way to conclude this brief look at the MSDS is with some advice from an expert. Jim Sweeney, a senior industrial hygienist in OSHA's Cincinnati area office with nearly 30 years of OSHA experience under his belt, offers several valuable suggestions about MSDSs:

• Expand your binder. If you use traditional binders to manage your MSDSs, consider including other helpful documents in the binder, such as a copy of the standard, your written hazard communication program, your chemical inventory list, and a glossary of technical terms.
• Don't keep workers in the dark. Sometimes third-shift workers are literally left in the dark when it comes to getting their hands on the MSDS binder, says Sweeney. That's because the document is locked in a supervisor's office only open during the day. The answer is to place at least one additional binder in a break room or other location that never closes.
• Train the troops. Make sure workers know how to find and interpret the safety and health information they need. Don't just hand them an MSDS and tell them to read it, or point to a computer terminal or a fax machine and tell them to find it.
• Keep MSDSs up to date. Sweeney recommends that you establish an orderly schedule for MSDS review to ensure that the sheets are up to date and reflect precisely what's in use.
• Hold on to old sheets. Don't discard MSDSs for substances no longer in use. Keep them in a separate file so that they can be consulted if it is learned, for example, that a component formerly used has been determined to cause illness.

Thinking of going electronic for your MSDSs? Many companies are doing away with cumbersome paper filing systems in favor of such electronic systems as online MSDSs, CD-ROMs, customized databases, and fax-back systems. For many companies, this is a sensible, cost-effective way to go. OSHA's on-board with the idea as well--as long as there are no barriers to immediate employee access. "Immediate access" means that, in emergencies, the MSDS should be available during the workshift when it was requested. In nonemergencies, it should be available by the next workshift at the latest.

What to look for in an electronic system. Whichever electronic MSDS system you choose, it should be:

• Reliable. Electronic systems must provide reliable access 24/7, if necessary. Even with a backup, you don't want a system that doesn't guarantee maximum reliability. Ask suppliers for references and then call to ask them about reliability and their overall satisfaction with the system.
• Easy to use. Check out any system you might be interested in to make sure it's easy to use. If it's too complicated, some employees may have trouble using it, and might, as a result, skip checking an MSDS when they should. To combat this, have employees at different computer skill levels try the system out and give you their impressions before you purchase.
• Accurate. Even if you buy a program from a reliable supplier, remember, according to OSHA, you're the one who's ultimately responsible for the accuracy of the information your workers get from MSDSs. That means you need to be certain the supplier provides complete, accurate, and up-to-date MSDSs without fail.
• Compatible with your computer systems. Whatever electronic MSDS system you choose has to be compatible with your hardware and software. Otherwise, you could be looking at expensive upgrades or crippling technical problems.
• Cost-effective. Compare the cost of maintaining a paper filing system with the cost of an electronic system. Are you going to be saving any money? If not, is the extra expense justifiable in terms of efficiency, speed, and improved employee access to essential safety information?
• Accessible to all employees who need it. If you use an electronic MSDS system, all employees who need to use MSDSs must have access to computer terminals or other necessary equipment and must be trained to use the system and the equipment correctly. If the terminals aren't right there in the work area, and if all the employees who use MSDSs haven't been trained in the electronic system, you're not meeting OSHA's immediate access requirement and are in violation of the Hazard Communication Standard (29 CFR 1910.1200).

Don't forget about testing and backup systems. If you use any kind of electronic MSDS system, it has to be tested regularly to make sure everything is working properly and employees are having no trouble accessing the MSDSs they need. Even if your electronic system is working perfectly, according to OSHA Directive CPL 02-02-038, you still have to have a backup system to provide MSDSs in the event of a system failure. Another electronic system can serve as a backup as long as it is not subject to the same problems as the primary system. For example, if a power outage will render your computer system inoperable in an emergency, you've got to have another reliable arrangement for contacting the chemical manufacturer, distributor, or other MSDS provider (for instance, by cell phone) until your electronic system is up and running again. Otherwise, an on-site paper filing system may still be necessary as a backup.