I have to first point out that OR-OSHA is a “state plan” ( and my personal favorite!) and is specific to employers in the state of Oregon (OR), but their 2020 LOI on maintaining SDSs electronically points out something that many (including me) have not considered. I have been telling all my clients for decades that we have to maintain a “hard copy SDS manual” for those times when we can not access our SDS electronically. But as OR-OSHA points out, in today’s technology we have surpassed the need for the “hard copy SDS manual” and it is possible to go 100% electronically… (emphasis by me)
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Essentially, as long as there are NO BARRIERS to employees accessing the SDS, storing them electronically is acceptable. However, if access to SDS is provided electronically, there MUST BE AN ADEQUATE BACK–UP SYSTEM IN PLACE in the event of a power outage, equipment failure, or other emergency involving the primary electronic system (e.g. interruption of internet connection). This backup system can also be electronic, but it MUST BE SEPARATE FROM THE PRIMARY SYSTEM AND NOT RELY ON THE SAME SERVICES AS THE PRIMARY SYSTEM, so that SDS may be accessed immediately in the event of an emergency. Therefore, it is not “mandatory to maintain hard copies of safety data sheets,” if all the conditions for your electronic system stated above are met. |
Solution? Have your SDS’s backed up on a thumb drive (now available up to 2 Tetrabits in size) which we can plug into a battery-powered laptop or a desktop with UBS. But know that our limitations are tied to the “battery-life”! In other words, if we have a 4-hour battery we could keep employees in the workplace for up to 4-hours; but once we are no longer able to access our SDS, it is time to regroup and figure out a plan. Typically employees are sent home during power outages of 4+ hours long, but when we only lose connectivity, many manufacturers who can operate without it, will do so – JUST KNOW that access to the SDS(s) is still required.
Source: https://osha.oregon.gov/OSHARules/interps/si-2020-01.pdf