SLC 2023 Preview: The Power of Safety Data Sheets

Sousa: Sure, several safety and non-safety professionals think that all SDS do is put them in compliance with the Hazard Communication Standard (HCS). That having them “checks off a box” if an OSHA Inspector shows up and wants to check their program. However, they are so much more than that.

They let the user know: the different ingredients and amounts that makeup mixtures; the hazards they present and precautions to take; first aid instructions; how to clean up the material if it spills; storage requirements; what PPE to wear when handling; valuable physical and chemical property information, such as pH, LFL/UFL and viscosity incompatibilities; and DOT, EPCRA and National Fire Protection Association (NFPA) information.

I equate the SDS with a Swiss Army Knife. Each section helps the safety professional answer a question, just as the knife contains different tools to help a soldier or outdoorsman solve a problem.

SDSs have served an important historical role in keeping workers safe from hazardous chemicals. How can SDSs be adapted in today's modern workplace, especially as the safety industry goes digital and remote?

I believe all chemical inventories should be digitized, and workers should be able to access that information online. However, this is only sometimes possible for two reasons.

First, you have facilities that fall under the Process Safety Management standard, so standard cell phones are not allowed in covered process areas. Those employers would need to provide Intrinsically Safe (IS) cell phones, tablets or computer terminals to access the SDSs, which is expensive.

Next, you may have team members who would prefer to use computers, tablets or cell phones to access information. It is not a one-size fits all solution. Management would need to talk to their departments and see how they would respond to digitizing their chemical inventory.

Whichever method one picks, the goal should be to provide easy and understandable access to chemical hazard information.

For the past few years, COVID dominated all safety efforts. If professionals have paid less attention to SDSs lately, what's one thing they should now revisit or update?

Safety professionals should work with each department to conduct a current inventory of all existing chemicals. See what is on-site and if it is still needed. If so, ensure that it is properly stored and secured. If not, pull it out and dispose of it properly.

Also, create a new chemical approval process if one does not exist. One part of the HCS that I see companies violate is buying new chemicals and having no vetting process. They buy it and bring it on-site, forgetting that now that the chemical falls under the HCS. Users need to be trained on its hazards and address other safety and health concerns.

What messaging do you use to communicate the importance of SDSs when talking with frontline workers, executives and other safety professionals?

If an SDS exists for that chemical, we should have it—even if it isn’t legally required. You never know how someone will react when exposed to certain chemicals, so it’s better to have it and not need it than need it and not have it.

Also, the EHS department should have the final say if any chemical is brought on-site. For example, there is no need to buy over-the-counter cleaning products that contain harsh chemicals and fragrances when there are several other cleaners that cost the same and work just as well but don’t contain the same ingredients.

What is something that safety professionals need to know but is often overlooked regarding EPCRA reporting?

Extremely Hazardous Substances (EHS) have different reporting requirements on the EPA List of Lists than SARA 312 requirements. Extremely Hazardous Substances (EHS) fall under SARA 302 and are all different values. (Chemicals that fall under SARA 312 have the default reporting amount of 10,000 pounds at any time during the year.)

Also, have accurate conversion factor tables for liquids and gases. Remember, Tier II forms ask for weights in pounds and not gallons (liquids) of cubic feet (compressed gases).

Do you have one SDS best practice you can share with the EHS Today audience in advance of your presentation at the Safety Leadership Conference?

I have two! First, see why your company’s chemical approval process is and ensure that you are part of it. If they don’t have one, start collaborating with management to show why one is needed and work with them to create it.

My philosophy is that if you get everyone involved in creating the process that affects them, they have no excuse not to use it. Next, find out supplier points of contact who can provide you with annual usage information. In my experience, knowing who these people are and explaining to them what you need early on makes life much easier when calculating quantities for your Tier II reports.

Your presentation will discuss a workplace fatality as a result of improperly mixing chemicals. What are some other, possibly more common, concerns and results of inadequate hazard communications?

Again, know what’s on-site. Ask those in that department when it was used last and if they still need it. Is there an accurate SDS on-site for it, and have those who use it been trained on its hazards? Finally, don’t hesitate to say no to bringing certain chemicals on-site. If they pose too many risks, explain that to the requesting department and work with them to find an alternative.

Sometimes, our job is to say no; however, don’t stop there. Show that department you are willing to help them find what they need to do their job with less risk to human health, safety and the environment.

What's one thing you hope attendees learn from your session at the Safety Leadership Conference?

They will look at SDS not as just some pile of papers but as helpful tools to strengthen their chemical hazard program. And by reading them, they may be able to offer a less hazardous substation or prevent incompatible chemicals from being stored next to each other.

If I can get just one person to say to themselves, “I am going to update my inventory, digitize my inventory or create an approval process,” then all the effort I put into creating and presenting my information was well worth it.