16 replies to this topic

[NorCalNate]

I completed my annual chemical inventory and there was a significant lapse in Policy resulting in a majority of chemicals not being on the chemical registrar or having an SDS. 

 

I've downloaded all the SDS that I need. If possible I'd prefer to avoid printing each SDS, was wondering if it would be acceptable to only have digital SDS files instead of printed ones? 

[PrplomSolved]

I completed my annual chemical inventory and there was a significant lapse in Policy resulting in a majority of chemicals not being on the chemical registrar or having an SDS. 

 

I've downloaded all the SDS that I need. If possible I'd prefer to avoid printing each SDS, was wondering if it would be acceptable to only have digital SDS files instead of printed ones? 

 

 

I think a more appropriate question is whether the SDS's would remain accessible from anywhere on-site in the event of power-outage, server failure, or other technology disruption. From an audit perspective, the primary concern with a fully digital system would be the existence of a documented and effective backup plan to ensure continued access for all.

[SQFconsultant]

If I'd a worker down on the floor at the location of use/storage will I know how to readily get to this information?  

 

We use both a screen with pics of each item - push the photo and get the sheet and also have the sheets in laminated sheet format at each location of storage/mixture and same system stores digital copies.

[Tony-C]

Hi NorCalNate,

 

As Austin has indicated this is more a health and safety issue than food safety.

 

I had a delivery of a caustic tanker once where the hose split and the guy unloading got sprayed. That SDS information etc, available first aiders and the location of an emergency shower were very important.

 

So, as Glenn has posted I would want laminated copies (of any information related to action required following accidents, other emergencies and spillages) available at point of use, acceptance and storage.

 

Kind regards,

 

Tony

[GMO]

One thing I often find is people forget to get the Technical Data sheets and only get the MSDS. The Technical Data sheets give you more information about the dilution, testing methods, suitability for different materials and absence of allergens (i.e. technical information). The material safety data sheets give safety information. Sometimes they're combined but not often I find at least over here.

 

I'm not necessarily of the opinion that printed is more easy to locate in an accident scenario and printed is more likely to be waylaid or out of date. One thing which might help is to have essential safety data at storage points and perhaps a QR code to where they're stored. Certainly only having hard copies or only electronic copies can both cause issues.

Also just out of habit and, I think, good practice, I will always have hard copies of things like this, factory plans etc at a gatehouse and in one other place on site in case of crisis situations where electricity or internet is put out of action.

[jfrey123]

One thing I often find is people forget to get the Technical Data sheets and only get the MSDS.

 

Stateside all of the chemical suppliers were required to drop the MSDS moniker and now provide SDS which provide the level of detail you're describing.  One of my first hits early in my career was having a MSDS binder still out on the floor after the regulations had changed to the SDS standard, and everything in it labeled MSDS was obviously out of date.

 

To OP's question, piling on for everyone else's reply, you'll want physical copies available for regular and emergency use.  Every one of your employees handling chemicals needs to have access to these, and it's not likely each of those employees has access to your digital storage spaces.

[GMO]

Apologies, MSDS is still used in the UK.

 

Just make sure those physical copies don't get out of date. I don't think I've done an audit yet where I've not found an issue with them. 

[Harminnie]

The following 2-part system has worked for our company and and the staff say it works well for them :

 

#1--A SDS spread sheet titled Chemical Inventory List & Risk Assessment BRC 4.9.1 with the following headers   :                         Product -Product #- Location- Who Uses? Where Specific e.g. machine (internal / external)- What used for -Chemical Physical State- Usage-Frequency- Food Grade Y/N- Likelihood of Direct product contact- Likelihood of indirect product transfer Risk Rating- Action required: Y/N/What- SDS page 1 in Manual Y/N- Allergen Statement present for Food Grade products Y/N.

                     --Food grade items are highlighted one color and Allergens are highlighted a different color.

 

#2 A SDS binder with the first page of the chemicals SDS sheet

 

 

 

[SHQuality]

The following 2-part system has worked for our company and and the staff say it works well for them :

 

#1--A SDS spread sheet titled Chemical Inventory List & Risk Assessment BRC 4.9.1 with the following headers   :                         Product -Product #- Location- Who Uses? Where Specific e.g. machine (internal / external)- What used for -Chemical Physical State- Usage-Frequency- Food Grade Y/N- Likelihood of Direct product contact- Likelihood of indirect product transfer Risk Rating- Action required: Y/N/What- SDS page 1 in Manual Y/N- Allergen Statement present for Food Grade products Y/N.

                     --Food grade items are highlighted one color and Allergens are highlighted a different color.

 

#2 A SDS binder with the first page of the chemicals SDS sheet

Why do you only have the first page of each SDS in the binder? How are people supposed to access any other pages?

Why doesn't the SDS spread sheet not include a version date to ensure they're all up to date?

[Hoosiersmoker]

As our company's Safety Manager, we moved to a completely digital system. We have a dedicated server that holds only active and archived SDSs in PDF format. All machines have a workstation kiosk with a touch screen that has a link to that server and is searchable from the screen. There are printers at numerous locations and each kiosk is assigned to a printer. I can go anywhere in the plant and within 30 seconds have a paper copy of the SDS in hand. It's much faster than SDS books or binders and much easier to maintain. Our low power (120V) systems have an on demand generator backup. BTW, if you can't get an SDS for a chemical but have an MSDS, you have to keep the MSDS. We have one chemical we still use that is no longer produced and we only have the MSDS available so, that's the only information we can keep on that chemical.

[SHQuality]

As our company's Safety Manager, we moved to a completely digital system. We have a dedicated server that holds only active and archived SDSs in PDF format. All machines have a workstation kiosk with a touch screen that has a link to that server and is searchable from the screen. There are printers at numerous locations and each kiosk is assigned to a printer. I can go anywhere in the plant and within 30 seconds have a paper copy of the SDS in hand. It's much faster than SDS books or binders and much easier to maintain. Our low power (120V) systems have an on demand generator backup. BTW, if you can't get an SDS for a chemical but have an MSDS, you have to keep the MSDS. We have one chemical we still use that is no longer produced and we only have the MSDS available so, that's the only information we can keep on that chemical.

When you have a binder, it is easy to get rid of the old version of any of the documents. How do you make sure no old printouts are used around your facility?

[Hoosiersmoker]

When you have a binder, it is easy to get rid of the old version of any of the documents. How do you make sure no old printouts are used around your facility?

What print outs? We don't keep printed versions of SDSs. We only need a printed version if a person has to be evac'd due to chemical exposure. They can be viewed as PDFs from anywhere in the plant at any time so there's no need to print them.

[SHQuality]

What print outs? We don't keep printed versions of SDSs. We only need a printed version if a person has to be evac'd due to chemical exposure. They can be viewed as PDFs from anywhere in the plant at any time so there's no need to print them.

You said "There are printers at numerous locations and each kiosk is assigned to a printer. I can go anywhere in the plant and within 30 seconds have a paper copy of the SDS in hand." How do you make sure none of the operators have printed out one or more of these and are using an out-of-date version?

[GMO]

You said "There are printers at numerous locations and each kiosk is assigned to a printer. I can go anywhere in the plant and within 30 seconds have a paper copy of the SDS in hand." How do you make sure none of the operators have printed out one or more of these and are using an out-of-date version?

 

I agree I've found deliberately hard copies available and often out of date for SDS (or MSDS and TDS in the UK) when sites deliberately choose to keep copies in first aid rooms etc (good practice but nobody owns keeping them live). The concern on the ability to print, doesn't this concern apply to any document or procedure? You could always watermark things with "uncontrolled if printed" on them or some warning to print off the latest copy?

[jfrey123]

Man, us QA people sure are good at poking holes in the methods or practices we don't like...     Not intended as an insult to any of us, we're all just set in our ways and worried about the potential gaps we see in other practices.

 

Personally, I like the binders.  It provides immediate access in an emergency, lets you quickly initial and date to indicate you have reviewed the documents right on the document, and keeps everything in a designated spot.

 

My main concern with storing electronically and printing as needed was access, which is because easily 90% of the people in any of my plants don't have a login to access a computer.  If people can overcome the access issue, great.  Then you deal with how to document that you've verified every SDS electronically each year (or whatever frequency you set via SOP).  Uncontrolled copies floating around randomly become an issue, so then you set the policy that every time you need to reference the SOP you must do it via a computer, and then people argue that becomes an unnecessary delay if there is an emergency.  But then, binders create a delay as well as you have to send someone to run to the one or two spots you normally keep them.

[GMO]

Man, us QA people sure are good at poking holes in the methods or practices we don't like...     Not intended as an insult to any of us, we're all just set in our ways and worried about the potential gaps we see in other practices.

 

Personally, I like the binders.  It provides immediate access in an emergency, lets you quickly initial and date to indicate you have reviewed the documents right on the document, and keeps everything in a designated spot.

 

My main concern with storing electronically and printing as needed was access, which is because easily 90% of the people in any of my plants don't have a login to access a computer.  If people can overcome the access issue, great.  Then you deal with how to document that you've verified every SDS electronically each year (or whatever frequency you set via SOP).  Uncontrolled copies floating around randomly become an issue, so then you set the policy that every time you need to reference the SOP you must do it via a computer, and then people argue that becomes an unnecessary delay if there is an emergency.  But then, binders create a delay as well as you have to send someone to run to the one or two spots you normally keep them.

 

You're right... Ultimately in this case, if it's a potential health and safety urgent situation, the fact an SDS is a bit out of date is unlikely to be a major issue in terms of the risk to health or at least less of an issue than having no SDS at all.

That's where (stuck in my ways Brit here) having separate Technical Data sheets (for techies) was helpful. They could be kept electronically, MSDS (as they're still called in the UK) can be printed out.

[TimG]

Some places need binders because we have employees who cannot operate a computer. Like at all. In a previous location we also had that issue and the safety director made everyone download an app that had our SDS's updated and on file. Of course, that app also tracked and reported data and wanted full phone privileges of employee's personal phones..

It was a good idea with an unfortunate outcome