Occupational Safety & Health Administration's Material Safety Data Sheet (MSDS) regulations and the Environmental Protection Agency's SARA Title III reporting requirements are probably among the leading cause of headaches for safety and environmental managers because they involve tons of paperwork.
OSHA's MSDS requirements fall under the Hazard Communication Standard 1910.1200 Section (g) and mandate that employers must keep MSDS - which contain information regarding the identity of the chemical, hazards, first aid instructions, and more -- on site for all hazardous chemicals in the workplace. And, all MSDS must be readily accessible to employees in books or electronic formats.
EPA's SARA Title III reporting requirements fall under the Emergency Planning and Community Right-to-Know Act of 1986, which mandates that facilities submit a hazardous chemical inventory form (known as Form-R) to the appropriate agencies for any reportable chemical that meets or exceeds EPA's threshold quantities. Any facility that meets or exceeds EPA's established threshold quantities, which is in pounds, must also prepare a report (known as Tier II) that identifies the chemicals and the amounts of each chemical kept in the facility.
Software tools can help
Obviously, completing all this paperwork can be overwhelming. But, help is available in the form of software management tools. From the simplest package to the most complex, software packages can help manage MSDS and reporting paperwork, says Dave Dively, director of sales and marketing for Corbus-PA, a Kennett Square, PA-based company that offers software management tools.
'With some software solutions, MSDS information can be input into the package, which then makes all the necessary information available in an electronic format,' says Dively. 'Users can print out MSDS to make updating their books easier or they can use available network versions which allow employees throughout a facility to log on and search the MSDS database when they need to.'
This can be a big help if OSHA comes calling. Industry experts explain that when OSHA visits a facility, the agent picks up a hazardous product and asks an employee to locate the MSDS for that product. If the employee can't find it, the company is fined.
And, network versions often eliminate the task of duplicating paperwork for large companies that previously needed to keep books updated at more than one location because the network system allows MSDS information for all the chemicals at each plant to be input in one central location and accessed at individual sites through the company's Intranet system.
Paul Jakubski, manager of corporate environmental and safety with Dow Jones in Princeton, NJ, says that using this approach has made MSDS management easier for his company, which uses the network version of Corbus' software in 17 of its plants. 'It has really made things simpler,' says Jakubski. 'In the past, we had to update books in each plant on a regular basis, but the NetMSDS system has eliminated most of that paperwork and made things simpler.'
Programs that handle environmental reporting also make compliance easier. For instance, some programs are able to examine a company's MSDS and inventory information, calculate the amount of each hazardous chemical on site, alert the users to the products that are reportable, and generate the proper federal forms. Industry experts estimate that doing this without software could take as much as 1,000 manpower hours.
Jakubski, who says Dow Jones has been using Corbus' reporting software, called TERMS, since 1996 to help keep up with New Jersey's rigorous reporting requirements, says: 'The tool allows us to see which plants have what ingredients and how they're being used, which has been a real time saver and a great resource.'
Investing in tools like these is worth it, says Jakubski. 'When we first initiated the program we did see a dollar savings, and over the years there has definitely been an ROI in management and administrative time,' he says.