I am currently researching different ways my Company can quickly and efficiently make accessible the Safety Data Sheets (SDS) to staff and emergency first responders during an emergency and was wondering if there was a preferred option? Is there is a requirement now that these must be available electronically as well as physically, what would be the best suggestion to provide this information in a safe and secure manner?
When it comes to Safety Data Sheets (SDS), there are regulatory requirements about how they are stored and accessed. We can look at regulation 156 and regulation 162 in the OHS Regulations 2017:
Regulation 156 - Safety data sheet must be readily accessible
(1) An employer must ensure that the current safety data sheet for a hazardous substance is readily accessible to any employee who may be exposed to the substance.
(2) An employer may make the current safety data sheet accessible to employees in appropriate languages in addition to English.
Regulation 162 Register of hazardous substances
(1) An employer must ensure that a register is prepared and maintained in accordance with subregulation(2) of all hazardous substances supplied to the employer's workplace.
(2) The register must contain—
(a) a list of the product identifiers of the hazardous substances supplied to the employer's workplace; and
(b) a copy of the safety data sheet for each of the hazardous substances supplied to the employer's workplace.
From the above we can see that the key is that SDSs must be readily accessible to people likely to come into contact with the hazardous substance. Indeed, the Hazardous Substances Compliance Code makes this clear:
98. An employer must ensure that the current SDS for a hazardous substance is readily accessible to any employees who could be exposed to the substance.
99. An employer needs to keep copies of SDSs in a location convenient to the work area in which the substance is used. Employers should also keep SDSs in languages other than English if appropriate. Commercially available SDS databases may be used provided they contain the manufacturer or importing supplier’s current SDSs.
106. The register needs to be kept in a central location and a readily accessible copy of it needs to be in each relevant work area. The register may also be computerised if employees know how to access and use the computerised system.
This can be in an electronic form, but it does not have to be. A digital or online version of the SDS is, depending on the workplace may be best way to make sure that SDSs are readily accessible, but should probably not be the only way. What are the contingencies in case of the internet or intranet being down. Nothing beats a filing cabinet/draw with a binder of SDSs at or by the place where the chemicals are being used.
As to where a Register of Hazardous Substances they should be stored online, most SDSs come from manufacturers or suppliers and are are commonly available online, so I am not sure of the need they need to keep their existence commercial-in-confidence. What the employer is trying to keep safe and secure is the key question? One idea would be to have an unlisted webpage on your publicly facing website where they are all linked in the form of a register – anyone with the right web address would have a complete list however it would not be searchable through the internet or via your website – you could give access through a QR code quite easily.