A call from NIOSHIn the early 1980s, I was working with a mining, manufacturing and construction concern in suburban Chicago when NIOSH came calling with a request - give them a chemical inventory. I was tasked with the dreaded assignment by our chain-smoking, "safety by the seat of your pants" safety director, who gave me this simple directive: "Give 'em what they want, but don't tell 'em what we have."
Along with the chemical inventory, NIOSH wanted specific information: manufacturer name and contact information, product name, chemical components listed on the label, quantities, container sizes, locations, whether we had an MSDS on file and, if not, what our process was to obtain one. They also wanted sample copies of our MSDS request letters, second request letters, Hazard Communication Program (formerly known as the Chemical Safety Plan) and any other information we could cough up.
Hurdles at every turnMy task was tougher than you may think. Remember, back then the Hazard Communication Standard was only in effect for manufacturers, importers and distributors and not yet for general industry or construction employers. Plus there were other hurdles:
- Our 40-plus facilities were spread over six states in the Midwest and East Coast regions.
- Our facilities ranged from old to very old to antique.
- Everything was stored everywhere in every facility.
- We had no Chemical Safety Plan, MSDS request letters or ways to track MSDSs or chemical inventories.
More 'N/As' than todayFor the next six months, I gathered the inventories. During that time I was also busy learning about the impending Hazard Communication Standard, preparing our management control plan, contacting manufacturers for product information, and submitting MSDS request letters and follow-up request letters.
Requests for MSDSs in those days were easily ignored or conveniently misplaced. Even the term "Material Safety Data Sheet" was unfamiliar. Many MSDSs I finally did receive were only a single, double-sided information sheet - often times with only one side copied, and even then it might be partially cut off while copying! The sheets contained many more "N/As" than we see today, along with bad information: gasoline was not a fire hazard; muriatic acid was not incompatible with anything; benzene did not pose a contact hazard.
Finally, after much pain, suffering and Viceroy smoke, the inventories were completed and submitted to NIOSH.
The payoffMost of what is taken for granted today as a part of the safety process was, back then, new and foreign. Though the federal initiatives were progressive and made good sense, they were different from the way we did business and, therefore, considered evil.
We would later learn that we were part of a NIOSH study into the amount of time necessary to comply study into the amount of time necessary to comply The first couple of years leading up to 1910.1200 cost me about that same amount of time, but it has paid off now as I believe the standard is an essential part of employee and personal safety, and we safety professionals must do everything we can to bring the information to our workplace.
To that end, in the past three years the management control plan at O'Hare Airport Transit System, Inc. has developed into a more user-friendly method for employees to find information. Incoming chemicals are logged into our SOMAX inventory control software, which has fields for whether an MSDS is required, if the MSDS is onsite and the manufacturer date of the MSDS. New and updated MSDSs, along with a transmittal form stating the reason for the MSDS, are forwarded to our assistant safety manager/MSDS coordinator.
Depending upon the outcome of the review, the MSDS may be made a part of our departmental MSDS hardcopy manuals, after it passes through our Document Control Department and our database of information. That database, available to all employees by specific chemical product and as a cautionary notation in work orders, reduces the MSDS information to the essentials - what it is, how it can injure or sicken you, signs and symptoms of exposure, self-rescue and emergency actions.
The return versus effort has led to a more efficient manner in dealing with MSDS compliance.
SIDEBAR: Avoiding HazCom pitfallsOne of the biggest pitfalls of having a clear, concise Hazard Communication program is maintaining up-to-date information on your constantly changing chemical inventory. Here are some suggestions to consider for an effective HazCom program:
1) Notify your vendors that with each new order they must provide a copy of the MSDS when the order is delivered.
2) Samples that vendors might leave with you for trial use should be refused unless they have an MSDS.
3) Communicate MSDS requirements to Purchasing, Supervisory and Management staffs.
4) Use a software program to keep track of your chemical inventory. There are many MSDS software products on the market. If you already use inventory software look for ways to integrate it with MSDS tracking and to generate MSDS Manual indexes.
5) Make MSDS manuals as simple as possible; try not to cross-reference too many times. Confused, frustrated workers will not search for hidden information.
6) Make department-specific MSDS manuals rather than having "master" MSDS manuals. This can provide workers with quick and timely information.
7) Identify the personnel and roles critical to the HazCom program and work with them to make it work. People should understand what you are trying to accomplish.
8) Long-winded training sessions will lead to a bored audience. Retaining information is key.
- Michael L. Schmick, assistant safety manager, O'Hare Airport Transit System, Inc.