Proper Safety Data Sheet (SDS) management is crucial for accurate regulatory reporting. Without a streamlined management system in place, key information may fall through the cracks. If your SDS is inaccurate, any regulatory reports using that information will also be inaccurate, which can lead to penalties, fines, or loss of permits necessary to conduct your business.
There are variety of tools available to assist you in SDS management. But you need to find the right resources for your company and the chemicals you use. A tool that isn’t a good fit can lead to reporting issues if it doesn’t provide the right data framework for your specific SDS needs.
The Importance of Accurate Safety Data Sheets
Facilities must have SDSs on site for any chemicals used or stored in the workplace. These SDSs contain detailed healthy and safety information on the chemicals that are used by employees and/or stored at your facility. SDS information is used for regulatory reporting to Federal, State/Tribal, and local areas of government. They also must be aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) according to OSHA 2012.
Accurate SDSs are especially important when it comes to meeting requirements under Title III or the Superfund Amendments and Reauthorization Act (SARA Title III), also known as the Emergency Planning and Community Right-to-Know Act (EPCRA).
The Community Right-to-Know provision helps increase the public’s knowledge and access to information on chemicals at individual facilities, their uses, and their releases into the environment. By working with facilities, state and local governments can use this information to improve chemical safety and protect both public health and the environment.
There are four main components of the EPCRA:
- (Sections 302 & 303 or SARA Title III)
- (Section 304 of SARA Title III)
- (Sections 311 & 312 or SARA Title III)
- Toxic Release Inventory (TRI) Reporting (Section 313 of SARA Title III)
Having accurate SDSs is essential to meeting the various requirements of EPCRA. Effective SDS management is key to keeping your SDSs updated and organized so you can report accurately.
Considerations for SDS Management Tools
If your company is in need of a new SDS management system for Hazard Communication or regulatory reporting, there are many factors to consider. Selecting the right SDS tool is vital to successful implementation across the company. You will want to make sure the tool you select fits your unique needs, is accessible to those who need it, and appropriately handles the data your company uses. Here are some key areas to consider.
Does the Tool Fit Your Business Model?
Your unique business model is the main factor in how your company operates, so you will want to make sure whatever SDS management tool you choose can be adapted easily.
Does your company operate at a top-down level? Or do the plants/facilities remain independent of Corporate and operate more self-sufficiently? Whatever tool you choose must be able to accommodate your business model.
Is the Tool Accessible?
If you have facilities operating in multiple countries, then you will need to verify that the application is multilingual in the graphical user interface (GUI) and at all available data points within the system.
If your operation is spread out across multiple locations, you will need to make sure that those who need to access the tool can do so without physical barriers caused by location.
Many popular SDS management systems are developed on a platform called Software as a Service (SaaS). This is a way of delivering applications over the internet. Instead of installing and maintaining software, you simply access it via the internet. All of the underlying infrastructure, software, and system data are located in the service provider’s data center. The service provider manages the system with the appropriate service agreement and ensures the availability and security of your data.
SaaS allows data to be accessed from any device with an internet connection and a web browser, allowing companies with multiple operating locations to access the same system without needing to have the software installed on multiple devices.
You may want to consider other accessibility factors as well, such as whether or not the software has a mobile application, or if there is 24-hour access to the SDSs for emergency and audit purposes. Ultimately, you want to make sure you will be able to access the data you need when you need it.
How Does the Tool Handle Data?
There are many factors you will want to consider when it comes to how a system handles data. Every facility has unique data needs based on their specific chemicals and products, so you want to make sure that the tool you select can easily adapt to the data appropriate to your SDSs.
Here are some of the factors you should consider:
- How does the system handle SDS updates?
- How does the system handle duplicate products within the database? Is there a consolidation process for duplicate products?
- Does the application allow for two-part products, such as kits? Can the database accept multiple values for one product? Many companies create one SDS for the overall kit with different formulations for Part A and Part B. However, this creates issues when an SDS system does not accept multiple values for one product.
- Can the SDS system maintain that chemical formulations and proprietary chemicals are managed on a user access basis?
- How does a system handle manufacturer changes, such as mergers, subsidiaries, and buyouts?
- How does a system handle product trade name changes or re-branding of a product line? How does it handle product code changes?
- Are you able to create departments and work areas for your locations?
- Does the system have an electronic material approval process?
- Can you generate needed reports from the SDS information?
- How does the system archive and retain records? SDS information must be retained for 30 years after use. Can archived products be queried and searched upon? This is especially important regarding possible lawsuits.
- How does the SDS system handle the same product classified by different regulatory agencies (i.e., HazCom 2012 vs. WHMIS 2015 vs. NOM-018-STPS 2015)?
- Does the SDS system created GHS compliant labels for secondary containers?
- Can the SDS system print a company’s SDS in bulk for departments, work areas, or at a corporate level?
These factors can play an important part in decision making. Making sure your chosen tool fits your specific data needs is essential. A tool that doesn’t work for you, or, even worse, makes your SDS management more cumbersome, can cause problems for your day-to-day operations and your regulatory compliance.
You will want to carefully consider how the tool handles data to make sure it is going to meet your company’s unique needs.
Get SDS Management Support
SDS management is essential for meeting regulatory reporting requirements for your hazardous chemicals and products. Without effective management, you may not be meeting regulations appropriately. Not only can this create regulatory issues for you and lead to fines, it may also mean you are subjecting your workers to unnecessary hazards.
If you need SDS management support, contact us at [email protected] to learn how Tetra Tech can assist you in fulfilling your company’s SDS responsibilities. We can help you select and implement an SDS management system that meets the needs of your company and identify the tools needed for successful compliance.