Electronic MSDS management is being adopted with increasing frequency. After all, anything has to be better than trying to keep binders of ratty MSDS pages up to date and in some reasonable order. Cumbersome, internally managed paper-based systems, demanding huge administrative resources, are being replaced by the efficiencies of technology and the Internet.
OSHA has clarified guidelines recognizing electronic storage and distribution of MSDS's as a viable option to replace hard-copy binders and file cabinets, opening the doors for both in-house databases and online MSDS's. This is good news for plant managers and safety officers. Technology can bring creative solutions to your business issues, but when your organization's compliance, employees' safety and company's reputation are on the line, you'll need to exercise caution and ask some tough questions. Working in the environmental systems industry for over 25 years, I have learned from many organizations some of the issues it is important to consider when choosing an electronic MSDS management system, and offer them here as a guide for getting started.
1. Does this solution meet the accessibility standards of OSHA's HazCom requirements?
A number of available solutions do not meet Right-to-Know laws. For example, 'fill-in-the-blank' database formats, where MSDS information is typed into data fields, do not comply. Also, depending on your needs, Fax-on-Demand may not be an option (see OSHA Hazard Communication Standard, 29 CFR 1910.1200). If an MSDS cannot be instantly accessed in the employee's work area, you will not be in compliance.
Compiled databases with generic or specific suppliers' MSDS's are not acceptable if they do not have your vendor's particular and most current MSDS's. Manufacturer/importer- and product-specific documentation is required, and approximations, generic MSDS's, outdated MSDS's and 'MSDS data,' even if it contains exactly the same information as the particular MSDS, are not acceptable for OSHA compliance.
2. Is the system/service provider 100% reliable?
You should be certain that the provider you select will implement a solution that can meet claims of 24/7 availability, zero down-time, adequate backup, speedy response and accurate documents. For example, OSHA has interpreted the term readily accessible to mean immediate, so a one or two hour delivery of an MSDS would fall short of this requirement, especially in the event of an employee injury or other emergency.
It is critical to consider who has control of your organization's MSDS database. This is important because you will always have ultimate responsibility to ensure it is accurate - you cannot transfer this responsibility to an MSDS service provider. Look for a vendor with a number of years of industry experience, as well as software and Internet knowledge, and ask for references from other organizations in your industry. Find out what guarantees are provided.
3. What are the technical issues surrounding implementation, maintenance, interfaces and MSDS storage/viewing formats?
It is a good idea to work with your IT department or resident Systems Manager to ensure the offered system will work in your technical environment without costly hardware upgrades or software customization. Instead of getting tangled up in a web of techno-talk, however, it may be beneficial to consult with an industry expert for an evaluation of the most effective solution to your needs. The power of the Internet can offer cost-effective alternatives to in-house systems acquisition, maintenance and support.
Sharing information with other facilities and groups within your organization, industry or community may be very valuable. Proprietary or confidential information, on the other hand, needs to be safeguarded. Security, accessibility and reliability are all very important.
Some technical issues to consider include: Technical specifications of software and architecture of the program; application/database/web server platforms and operating systems required; Internet access; scalability of the systems to grow with your company; ability to convert or export any existing MSDS data into the new system; ability of the new MSDS system to interface with enterprise systems and customization required to do so; and applicability of the program as an enterprise-wide solution.
4. Does this answer the need for your employees and business processes? How much work will it take you or save you?
Consider which of your employees need to have access to MSDS's. Is language an issue? When and where do they need access and what computer systems are available? What information do they have or need when searching for and accessing MSDS's? For example, a manufacturing line worker may not have immediate PC or Internet access in the work area, or may not know the exact name of the product used in a particular process. Will this employee be able to access the MSDS they need nevertheless? At Eaton Corporation, Chemical Safety set up PC's in plant cafeterias and other open-access areas where simple, handy MSDS access encourages employees to understand product hazards and safety. At Boeing, Nike and Xerox facilities, MSDS's are accessed by hundreds of employees on their desktop or shared PCs with network and Intranet (internal company Internet) applications. For some facilities, MSDS access screens and MSDS documents are available in multiple languages. These types of solutions drive to the heart of the issue at which OSHA's HazCom programs are aimed.
Will the EH&S or Safety Officer be able to create documentation required for regulatory reporting or for an inspection? What other needs might be required by your particular industry, facility, regulatory climate or corporate policy? Be sure the MSDS system you choose is flexible and will meet these needs.
When making a decision to buy an MSDS system or subscribe to a service you should understand how easy or difficult it will be to build your initial database and ensure it stays complete and up-to-date. You should know how much of this work you will have to do, and how much you want to turn over to your service provider. If you are doing the work in house, are tools provided to make it fast and easy? Can updates be automated? There will likely be compromise to balance simplicity, service, responsibility and cost. Determine your priorities and choose your service provider accordingly.
5. Is the system cost effective?
Cost may be one if the biggest factors in your decision to buy an MSDS system at all, and in which of available offerings to purchase. It is important to consider cost from two angles.
First, how much is your current MSDS Management system actually costing you in administration, risk and liability, and how much of that can be reduced with an electronic system? Be sure to consider all true costs in this analysis. These may include administration, time of employees when retrieving MSDS's, employee safety liability, risk of punitive fines for non-compliance and other hard and soft costs. Contact Chemical Safety for a free worksheet that can help you determine actual MSDS management costs.
Second, what is the tradeoff between the benefits offered by a system and the cost of that system? You may choose a comprehensive system that 'does it all', or look for a simpler system with a lower price. Some providers will work with you at different levels of cost/service, offering optional program expansion in the future. You will need to consider the pros and cons of working with a software, database or online application provider, and between self-maintenance and full-service.