“Oh no! We have a serious problem. The plant office manager ran into my office with a frantic look of panic on her face. The company safety inspectors are here and they want to see an MSDS on the Wite-Out. What will we do?”
Although this article written by Greg Klima titled “MSDS Gone Wild!” never explains if you really do need an material data safety sheet (MSDS) on Wite-Out, it’s a side of hazard communication that you don’t see too often, and it’s an interesting insight into an alarming scenario.
The story plays out like this: you are scrambling through your binders or your MSDS database of chemicals (just like about a thousand other safety professionals do every year when safety professionals show up). You are panicking because you have been taught to believe that you need an MSDS on every chemical in your facility, including Sally’s mayonnaise packets, Timmy’s aspirin, and Billy’s cosmetic dental floss, and the author’s advice while this hectic scenario plays out is to:
It’s true that the purpose of the hazard communication standard is meant to set rules to inform employees of risks which they are exposed to when working with potentially hazardous chemicals, but while the intentions of this basic rule of haz-com makes us keep our binders and databases updated in the event of an emergency or a facility audit, we have perhaps become almost too good at this practice. We now may have MSDS on items we don’t necessarily need to have them for – the truth is we do not need to have an MSDS on every single chemical in our facility. Once we determine which items not to worry about keeping on file, the easier it may be to maintain records. It’s that simple.
When Do I Not Need an MSDS?
If you check OSHA’s 29 CFR 1910.1200, you’ll see that OSHA is very specific about exceptions to its application and scope. MSDS are only one form of hazard communication. Two additional ways to inform employees about potential risks include container labeling and employee training. Other details include what chemicals are exempt from this rule (29 CFR 1910.1200(b)) and which categories of hazardous chemicals do not apply (29 CFR 1910.1200(b)(6)). Knowing what to be worried about now might save you some fretting in the future.
At KPA, we can help you maintain and update your facility’s MSDS database and chemical inventory as well as provide training and expert advice to help you support a safe and healthy workplace. With seven EHS services, we can help you comply with DOT and MSDS and hazard communication requirements all the way up to a complete environmental, health, and safety program. Each KPA service consists of a combination of online software, on-site services, function-specific training, and expert consulting necessary for a complete compliance program. Contact us to learn what level of support is right for your business.