What constitutes a barrier to access for SDSs?
Employers must ensure there are no barriers to immediate employee access of SDSs in each workplace.
The OSHA Hazard Communication Standard, 29 CFR 1910.1200, paragraph(g)(8) says:
“The employer shall maintain in the workplace copies of the required material 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, microfiche, and other alternatives to maintaining paper copies of the material safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.”
What constitutes a barrier to access?
- Keeping your SDS library in a place that is locked or not immediately accessible
- Having to rely on another person to provide you access to an SDS
OSHA again says “Employees should not have to ask for an SDS, as this could be perceived by employees as a barrier to access. For instance, if an employee must go through a supervisor to receive an SDS, the employee may feel that this singles him or her out. This could very well dampen the employee’s resolve to seek out necessary hazard information.”
There is no specific time limit used to determine whether an access barrier exists. The OSHA inspector will interview employees to ensure that they have “ready access” to the safety data sheets and have been trained on the chemical hazards in their workplace.
