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Safety And Security

Cost-effectively Improve hazard communication compliance

September 19, 2010
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Exposure to new drug-resistant pathogens is not only a reality facing the health care world.

Recent outbreaks of methicillin-resistant Staphylococcus aureus (MRSA) and vancomycin-resistant Enterococcus (VRE) have occurred in grammar schools, colleges, correctional facilities, and health clubs across the country.

As a result, there is heightened regulatory interest in cleaning and sterilization practices, leaving many building service contractors (BSCs) under the close eye of the Occupational Safety and Health Administration (OSHA).

Staying within the lines
In particular, BSCs must be in compliance with OSHA’s Hazard Communication Standard (HazCom), requiring their staff to be trained about the biological and physical hazards associated with the chemicals they use.

Obviously, cleaning and maintenance professionals use more chemicals during their workday than almost any other occupation, so it comes as no surprise that Hazard Communication violations are among the most frequently cited violations in the cleaning industry.

And, while HazCom’s overall goal is to help keep workers safe, it has created a costly administrative headache for BSCs trying to comply with the standard.

Managing a compliant Material Safety Data Sheet (MSDS) library is central to this challenge.

MSDS serve as the primary tool to identify the potential hazards associated with a chemical.

Most BSCs currently rely on paper-based systems, maintaining dozens of paper-stacked binders in janitorial and maintenance closets.

Keeping an up-to-date inventory for all of your accounts, varying chemical solutions, and changing products is virtually impossible with paper-systems.

OSHA “paperwork” violations, in particular MSDS, are among the most frequently cited during inspections, resulting in citations and subsequent fines.

Already facing stringent regulations, rising labor costs, and tight budgets, many BSCs are realizing the benefit of adopting Internet-based technologies to reduce both hard and soft costs of managing a paper-based MSDS library.

Not only do these systems satisfy HazCom’s “readily accessible” requirement, but they also offer instant access to MSDS information, in turn reducing the likelihood of serious injury or illness from chemical hazards and eliminating risks and liability associated with non-compliance.

Why not stick with paper?
Keeping up with the paper trail associated with a compliant MSDS inventory is a daunting task.

OSHA requires that you have an MSDS on hand for every product that your company uses, and that these documents are made readily accessible to all work shifts at all sites.

With paper-based systems, it is often difficult to have confidence that your MSDS inventory is OSHA-complaint.

Not only do you need to keep your MSDS library current and accurate, but every copy of your MSDS inventory must be maintained as well.

It is up to your staff to make sure the MSDS is properly returned any time it is referenced.

MSDS are often misfiled or never returned at all.

Such errors typically do not become apparent until an incident occurs or a facility is inspected.

On the surface, a paper-based system doesn’t seem like a huge expense; however, industry estimates suggest that paper-based systems can cost as much as $15 per MSDS document per year.

It doesn’t take too many MSDS for that cost to affect your bottom line, not to mention the potential lost work time, workers’ compensation claims, non-compliance penalties, and possible litigation fees.

It’s easy to see why more and more BSCs have or are looking at implementing an electronic MSDS management system to maintain their HazCom compliance procedures.

Going digital
BSCs are finding electronic MSDS management to be a beneficial tool in reducing the burden associated with traditional paper-based systems.

Not only do these systems offer increased availability for all sites to access MSDS information, but they also simplify the administrative tasks associated with organizing and maintaining compliant MSDS inventories and generating required reports.

With a paper-based management system, documents can only be indexed by one or two words and consequently searched by one word, such as the product’s name, its manufacturer, etc.

This means that once an MSDS is indexed by that word, it can only be located that way unless a cross-index is created and maintained.

In a time of crisis, a paper-based system can become a costly one.

Most online services give you the ability to search for an MSDS based on multiple indexing capabilities.

This gives users numerous fields to choose from when searching, making it easier to locate an MSDS in a matter of seconds.

As a result, risk and liability are significantly lowered.

In an emergency situation, this capability is invaluable.

Another benefit of electronic MSDS is version management.

The time it takes to go to multiple binders or filing cabinets and replace MSDSs in an effort to stay compliant and up-to-date can easily be reduced by having all of your MSDSs in one easy-to-access place.

Not only does it save you time, it also saves you money.

The savings gained from an electronic MSDS management system are the most obvious benefits.

Think about how many times an MSDS is misfiled or lost, necessitating a replacement.

An electronic system that’s tied to a large MSDS database will allow for almost instantaneous updates or replacements with considerably less time and effort.

And, with the click of a button, you can see how compliant you are, making MSDS management and your overall safety program more efficient and cost-effective.

What’s more, these days electronic management solutions are surprisingly affordable, starting at just a few hundred dollars a year.

Is electronic management compliant?
Obviously, compliance is one of the most important things to consider when talking about an electronic MSDS management program.

With OSHA fines in the tens of thousands of dollars, it’s important that you understand how to keep your workers safe while being compliant.

The OSHA Hazard Communication Standard (CFR 1910.1200) requires employers to “ensure that MSDSs for all hazardous materials at the facility are readily accessible to employees while in their work areas.”

OSHA’s biggest concern is that you meet their requirements and follow the regulations.

They don’t regulate how you manage your system.

Electronic management is not only compliant, it is the best way to manage your MSDS provided you have a back-up means of accessing them should you have a power outage or other emergency.

And you should have a back-up plan in place, regardless of how you are managing your MSDS.

Tips for evaluating an electronic MSDS system
First, make sure the system you choose meets OSHA compliance requirements for an electronic system.

The key is to make sure the system provides a backup capability.

If you’re looking at web-based systems, make sure there is a local backup capability, giving you access to your MSDS in the case that you can’t access the Internet.

Look for systems that provide dynamic databases to ensure you always have access to new or updated MSDS versions.

Also, look for a vendor that offers both “do it yourself” options as well as a services component to help you build and maintain your inventory.

This keeps you in control of your inventory and provides flexibility to add MSDSs when you need to.

Safety isn’t just in numbers.

Users should look for a system that not only provides a large MSDS database, but also ensures a consistent, reliable quality of those documents.

MSDS should always be current and the service should be frequently updating MSDS to guarantee the most accurate, up-to-date inventory.

It is important that all of the documents are manufacturer originals — re-keyed MSDS take the liability off the manufacturer and place it in your hands — whether you choose an online or software solution.

Also, when looking at Internet-based systems, ask about security since MSDS and the related information may be considered proprietary information for many companies.

Most importantly, make sure you choose a system that is easy-to-use.

If the system is not intuitive and requires a lot of extra training, it won’t get used.

Finally, when choosing an electronic MSDS solution, make sure you maintain ownership of your MSDS and any associated data.

Unfortunately, some systems are proprietary and don’t enable users to export their data in the event that they need to change vendors or go in a different direction.

Research your options.

Fortunately, there are many to choose from and you’re sure to find a system that meets the unique requirements of your company.


Glenn Trout is president of MSDSonline® (www.MSDSonline.com), a Chicago-based company that develops on-demand products and services, which make it easier to access, manage, and deploy Material Safety Data Sheets (MSDS) and other critical safety information. The company’s mission is to help its customers improve employee safety while saving time, lowering costs, and reducing the risk/liability associated with meeting stringent compliance standards.
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