Often times one of the most overlooked components to an electronic SDS management system is how to access specific versions or archived SDSs. This however, is an extremely important aspect to managing chemical hazard data.
OSHA’s record retention law in the most basic terms means, “you” need to be able to identify which chemicals and hazards your employees were exposed to, when they were in the workplace.
Let me try and lay this out in a real world situation.
So, an ex-employee has an illness; an attorney reaches out to you on their behalf. You go into full scramble mode—who is this employee; when and where did they work in your facility and more importantly; what chemicals where in their area as the attorney is implying their illness is directly related to exposures in your workplace.
This means that the OSHA record retention law is directly impactful and you need to put your hands on which chemicals and hazards associated them were in the workplace during a finite timeframe to answer these questions.
Two terms come to mind in our industry—“versions” and “archives”. Due to manufacturer’s changing the formulation, hazard classifications, and information on SDSs (which is the standard documentation most organizations user to retain chemical hazard data) you might have 1000 MSDSs (yes soon to be SDSs which puts a bigger spin on it) for the 350 hazardous chemicals actually used in the workplace. These 1000 documents are from 5-15 pages long; have revision dates and if this is your method of record retention must allow you to “put your hands on them”.
Versions are updated documents for the same material that have had significant changes to them. Very important if the manufacturer realized there was a hazard, changed the formulation; and thus reduced exposures; and limiting your organizations liability as a result.
Archives are records (including versions) of materials no longer in use in your facility.
If you can’t put your hands on versions and archives; you truly can’t be compliant and you can’t reduce your organizations risk. Ask me how SiteHawk meets these requirements in a way that no other company in our industry can!