The Importance of Staying Current
By Susen Trail | 09/22/2021
Over time, sometimes a very short amount of time, your safety programs and/or your chemical inventory will not include hazards and conditions your employees experience in your workplace. Sometimes your chemical inventory will be accurate but the Safety Data Sheets, SDS, has been revised and is no longer correct for the chemical being used.
You can find a cornucopia of workers and civilians in surrounding communities adversely affected, sometimes severely, by explosions and toxic clouds, as shown in the picture in the Chemical Safety Board's website (by searching Incompatible Chemicals). Section 10 of the Safety Database is required to contain information on the chemical's Stability and Reactivity. If this data is not current, non-hazardous processes can suddenly become the sum total of your company's reputation.
The Hazard Communication standard requires that all SDS' include the date of preparation or the date of the most recent revision. Sometimes this is at the top of the SDS but it always has to be included in Section 16, in Other Information. Having information on chemical hazards and controls is so important that it is stated in both 1910.1200(g)(1) and 1910.1200(g)(8) of the Hazard Communication standard. This means each workplace must have a logical and functional plan to ensure that the SDS arriving with a shipment of chemicals currently used in the facility has its revision date compared to the SDS currently on file.
Simple Safety Coach subscriptions include the Hazard Communication Program Wizard. Use of the Wizard is equivalent to an in-depth course on the standard, it's requirements, best practices, and information on practical implementation of the required actions so that you create a written program, complete with training, that will work seamlessly within your workplace and avoid common mistakes and gaps in implementation.
One of our instructions is to use Job Titles rather than names because, when Fred retires, the next person in that Job Title will need to know his tasks in keeping the workplace safe. Below is the coaching we provide in preparation for asking who to designate as the 'person' responsible for chemical Inventory and SDS Maintenance.
The inventory must be kept current. You can’t manage a chemical if you do not know it is there. Not only that, but managing a chemical that is no longer present wastes time and resources. It should be deleted from the inventory and the SDS dated and moved to the archive.
When a company has a change of address or name it will send a revised SDS with the next shipment. You need the most recent information in case you have to contact them. A company will also send a revised SDS when there is a change in the chemical composition.
A change in the chemical composition can affect the chemical's storage, compatibility with other chemicals, etc. At worst, it can create a fire or explosion if you don't change workplace conditions.
There should never be two chemicals with the same name and different hazards where your employees can get their hands on them.
Where there is a change or increase in the chemical hazard the new chemical must be segregated until the old chemical is completely gone.
Once every container of the old chemical has, like Elvis, has left the building, the Safety Data Sheet is replaced with the new SDS. The previous SDS is dated and archived.
It is most efficient to have the same person responsible for the chemical inventory also manages the Safety Data Sheets.
Something to consider: How will the employee responsible for the inventory and SDS management be notified of new chemicals, changes in the SDS, and about chemicals no longer present in the workplace in order to update the inventory and SDS?
Enter the job title in the field below for the role that will:
- Maintain an accurate and current inventory of chemicals in employee work areas, company storage areas, company vehicles, and offsite work areas.
- Be notified when a chemical order is placed or when a chemical is no longer in any facility or vehicle and will update the inventory list accordingly.
- Ensure that the most recent revision of the Safety Data Sheet for every chemical on the inventory is accessible to employees.
- Remove and archive Safety Data Sheets that have a revision in:
- Company contact information
- Chemical composition changes that do not affect the hazard type or severity
- Notify the Safety Manager when the revision includes
- Chemical composition changes significant enough to increase the level of hazard
- Chemical composition changes significantly enough to change the hazard type
- Remove and archive the Safety Data Sheet when the chemical is no longer present in or on any company property