Once again during this unprecedented time of lockdowns, quarantines and social distancing, it's time for Compliance Professionals to look at those jobs that you almost never get around to.
This time let's review your safety data sheets (SDS).
This idea comes from an ongoing series of blogs that originated from "26 Ideas for Working from Home for Compliance Professionals".
Most organisations have a simple process of collecting safety data sheets and dumping them in a folder. That folder just sits on a shelf collecting dust.
But they don't necessarily review the SDS, check they are being followed and check that they are updated over time.
Reasons for Reviewing the SDS
There are good reasons for reviewing your SDS.
- Suppliers are required to periodically review, revise, and update their SDS.
- Changes are made as new hazard information is found. This could be new information about protective measures, or changes are made to product information (i.e. composition or use).
- You could be caught out when these change and you don't know about them.
How do these changes affect you?
- Changes may change the way you store and control them on your site.
- You want your staff to be protected and they use the correct personal protective equipment (PPE) for the chemical they are handling.
- In case of emergency what are the correct steps your staff should follow.
- Emergency services need the latest information when they are onsite.
So how can you make this process just part of our normal Health and Safety activities and that it doesn't feel like another compliance time waster.
Step 1 Identification - This will be the most time consuming step in the process but only needs to be done once.
- Create an SDS register
- Do an audit of the site to identify what you have, where it is and quality, every department can help you with this.
- Ensure you have a SDS for each hazardous substance identified and the issue date of the SDS recorded on the register. If the SDS is older than 3 years, for example, ask the supplier for a new one. These days suppliers have good processes for supplying SDS when asked, some even attach them to deliveries. So ask your purchasing department to make it a requirement to supply one with the supplier's despatch documentation.
Step 2 Review - Are you controlling your hazardous substances correctly?
- How do you know you are you storing the hazardous substance correctly? Use an online tool and enter the details and it will produce you a report with the issues to be corrected (a great example is the Hazardous Substance Calculator from New Zealand).
- Check that the correct PPE is available and being used appropriately.
- Check that the hazardous substance requires special processes to be documented and your staff are trained in those special processes.
- Decide if your evacuation plan needs to include special hazardous substance controls.
Step 3 Monitoring and Changes
- Review your SDS based on the frequency of review defined within your country or state (this link will help you determine the frequency of review).
- When hazardous substances are delivered to site, make it part of the inwards department job to check if the SDS is still current. This will mean the SDS are being consistency reviewed.
- Have a central location where SDS are filed.
- Mmake it an agenda item in your Health and Safety Committee meeting where you review the process to ensure it is effective. Ask if anyone knows of new hazardous substances that have been introduced. Even ask if some hazardous substances can be replaced with environmentally friendlier alternatives.
- Sort your database or register to identified SDS that are going to be outdated shortly.
- Use site observations and audits to check that your SDS and their controls are being followed.
SDS reviews are never ending process but building it into appropriate processes when reduce the feeling of compliance overload.