Did you know that Hazard Communication violations were the second most frequently cited violation in 2015? Besides being plentiful, these violations are also expensive! On August 2, 2016 OSHA increased its penalties for all violations, including those related to Hazard Communication Standards. What once was a penalty of $7,000 per violation has now increased to $12,471 per violation. Willful or repeated violations have increased from $70,000 to $124,709 per violation. Add to this the fact that OSHA’s 2016 operating budget was increased by nearly $40 MM, giving it greater enforcement ability, and your practice is left with one potentially pricey predicament…
All of this simply means that maintaining an organized set of compliant Safety Data Sheets is of paramount importance if we’re to avoid the costly penalties of non-compliance. Safety Data Sheets (SDSs) are one of the primary tools used to communicate chemical hazards, and thanks to cloud storage solutions and the ubiquity of mobile devices, maintaining and accessing these sheets electronically has never been easier or more convenient! This electronic approach to SDS upkeep has a number of significant advantages over traditional hard copy storage – here are 3 such merits!
1. Greatly Enhances Organization
With OSHA’s requirement that offices maintain chemical identity records such as SDSs for a period of 30 years, one of the most salient benefits of storing SDSs electronically is the organization that it creates. If you’re storing SDSs in a binder, you already know how overwhelming it can be to organize and manage these documents – especially since they’re frequently updated. As you know, OSHA inspections come without advanced notice, and SDSs must be retrieved immediately during an audit, in order to demonstrate that they are “readily available.” While it may seem trivial, failure to locate an SDS immediately demonstrates that the document is not readily accessible, and could leave you with a $12,471+ fine.
The worst time to find out that your glutaraldehyde sterilant’s SDS was mistakenly filed in your binder under the letter “H,” instead of under the letter “G,” is during an inspection. Thanks to the ease of navigation and immediate retrieval ability—from nearly any location—electronic cloud storage provides, this costly scenario can be avoided altogether!
2. Saves Money on Cost of Maintenance
Besides the monetary costs of the fines themselves, there’s also the cost associated with paying staff to maintain a binder of hardcopy SDSs. “Maintenance” isn’t simply a matter of organizing the documents, but also includes the more tedious and time-consuming task of ensuring that the most recent version of each SDS is present. This may require contacting the supplier of the product on a periodic basis, and, if purchasing through a distributor, contacting the manufacturer. (Some distributors are not required to maintain an SDS themselves, and even if they do, OSHA only requires that manufacturers and distributors provide an updated SDS with the first shipment after the SDS is revised.)
Here’s a hypothetical scenario to illustrate this point:
- You order a new chemical product in January, which includes the most recent SDS available at that time.
- In March, the supplier updates their SDS to include revised Personal Protective Equipment (PPE), based on a study that shows nitrile gloves provide a more effective chemical barrier than latex gloves.
- Your current SDS only recommends latex gloves, and your employees continue to use only latex gloves.
- All is well until July, when one of your employees complains of having dry, cracked, sore hands after using this particular chemical product—little did she know that small amounts of the chemical had been passing through the latex material all along, coming in contact with her skin!
- You read the SDS, which states to use latex gloves, and you advise your employee that she is already following the recommended PPE and should simply wash her hands more often.
- In September, when you’ve consumed your existing supply of this chemical, you place another order and now finally receive the revised SDS (which has been available since the previous March).
Regardless of whether the exposed employee files a complaint with OSHA, you’ve allowed your employee(s) to use improper protective equipment for a period of six months after the revised SDS was released. Store SDSs traditionally and this scenario could only be avoided by dedicating a staff member to the task of SDS procurement and maintenance, which takes several hours per week, at a minimum. Store them electronically, and those required resources are dramatically reduced.
3. Frees up Employee Time for What Really Matters
Speaking of using dedicated staff to maintain your SDSs on a regular basis, how much are you paying your staff to perform this non-revenue-generating activity? Do they have the necessary training and expertise to obtain and evaluate a Safety Data Sheet? Does your staff understand the significance of Personal Protective Equipment and Occupational Exposure Limit data in Section 8? Can they, for example, recognize a now defunct, non-compliant ANSI-formatted SDS, from the currently accepted OSHA Hazard Communication 2012, a.k.a. “GHS” format? What revenue-generating activities could they be doing in your office instead of calling chemical manufacturers and distributors, organizing binders, removing outdated versions, and placing them in an archive, etc.?
If any of these questions give you pause, perhaps it’s time to consider outsourcing this complex work to a third-party SDS management firm. Third-party SDS management not only offers the benefits of electronic management and cloud storage (ease of access, ease of navigation, portability, etc.), but also provides peace of mind, due to the improved compliance achieved by having a team of dedicated regulatory experts managing your SDS library. Now that your staff is no longer spending several hours per week on regulatory compliance, how much more time can they focus on revenue-generating activities, such as insurance billing and patient care?
AutoSDS Powered by GSM
While complying with the OSHA Hazard Communication Standard certainly comes at a price, that price can be substantially reduced by managing your SDSs electronically. Patterson has partnered with Global Safety Management (GSM) to bring you AutoSDS, a new online database of Safety Data Sheets specific to your practice. Together we’ll help you meet OSHA’s compliance requirements of today, as well as prepare you for the requirements of tomorrow. If regulatory compliance makes your teeth chatter, rest assured that AutoSDS is there to help, with a staff of qualified regulatory experts standing at-the-ready to assist you.
- Click here to learn more about AutoSDS
- Click here to request a free, 15-minute demonstration
- Click here to sign up for AutoSDS powered by GSM
Maintain your safety data sheets electronically, and benefit from the increased ease of access and navigation, improved regulatory compliance, and the ability to allow your staff to focus on revenue-generating activities, this approach makes possible…it just makes “cents!”
- OSHA Hazard Communication, 29 CFR 1910.1200(g)(6)