Q&A: Requirements for storage of safety data sheets
Do facilities have to have a physical SDS binder or is it acceptable to have the files on a shared computer network drive that all facilities can access at any time?
Per 29 CFR 1910.1200(g)(8), “[t]he employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted if no barriers to immediate employee access in each workplace are created by such options.)”
So, the use of electronic access to SDSs is acceptable, but keep in mind the following:
There can be no barriers to employee access to the SDSs, which means the equipment to access the electronic versions of the SDS must be readily accessible to all employees in their work area, and all employees must be properly trained in the use of the equipment, including any specific software.
If there is a power failure or access to an electronic SDS database is disrupted in any way, the SDSs are no longer “readily accessible” and you are out of compliance. Therefore, if SDSs are maintained electronically, the employer should have a backup procedure or system (e.g., paper, another electronic system) for accessing SDSs in case the primary electronic SDS management system fails. And again, there can be no barriers to accessing the backup system.
The employer must ensure employees can obtain hard copies of the SDSs, if needed or desired.
In case of emergency, the employer must ensure that mechanisms are in place to immediately provide emergency response personnel with hard copies of SDSs.
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