Despite the myriad perceived negatives around Material Safety Data Sheets, MSDS compliance — along with chemical labeling — are the cornerstones of your hazard communication program.

Many of us view MSDSs as a sort of necessary nuisance. Opinions run the gamut from “they are too labor intensive to keep track of,” to “nobody looks at them anyway.” The truth is, not counting a paycheck, the MSDS is one of the most important documents an employee can have at his disposal in the workplace. When a hazardous material incident occurs, there is no better tool for quick guidelines to medical treatment and mitigation than the MSDS.

Yet another complaint I have heard over the years is that MSDS compliance is just too expensive. This is usually bemoaned at the same time thousands of dollars are being spent on a canned MSDS software program that was purchased over the phone after a quick dog-and-pony Web tour or trial offer. This invariably comes with the guarantee that your MSDSs can finally go paperless. With all their bells and whistles, these programs seem like a great idea to get out from under the work of doing it yourself … until your search for a product comes back with a “Not Found” message. Suddenly that grandiose claim of “Over 500,000 MSDSs in Our Database!” doesn’t mean much. Because CFR 1910.1200 still states that MSDSs must be “readily accessible” to employees, your multi-thousand dollar, paperless software bundle has just become a paperweight.

The secret of simple So, you find yourself with little or no funding for your electronic MSDS project. The directive is for paperless, electronic distribution that follows the intent of the standard. About 10 years ago, I was faced with the same daunting task by my manager: “Get us MSDS compliant — yesterday!” After the smoke cleared, I chose the electronic approach and came up with an idea that was so simple, I thought to myself, “How come I haven’t heard of this before?” While others may have already discovered this simple secret, I will share it with those whose lamp of inspiration has long burned out on the topic.

So what is the big secret? Not much, really. The answer is simple: a spreadsheet, hyperlinks and an image file library. While it may not be packaged in fancy formatting and slick Java applets, this system works just fine. What’s more, I have proven it to work in a company that, at the time, had nearly 6,000 MSDSs in its library.

Electronic MSDS 1-2-3 First, make sure your technology infrastructure has available space for you on your company or organization’s global or employee-access network drive. The needs of disk space are relative to the amount of information to be saved on it, so to enhance your sales pitch, make sure you select an image type that can be saved with the smallest file size without compromising image clarity.

Next, you must have a computer and a scanner. They can easily be had for under $1,000. Chances are you’ve already got one or both.

Like any other computer-based project, the initial setup is the most time and labor intensive. Presuming you have already completed a hazardous materials inventory and have acquired a hardcopy MSDS for each chemical or substance, the next step is to begin scanning the MSDSs and saving them on your network drive (ex. G:\Safety\MSDS). Many companies now have MSDSs for their products on their Web sites, so checking for the latest version is now easier than ever. In a pinch, you can download the MSDS to fill missing items from your physical inventory as necessary. As for labor considerations, think about using employees from your workers’ compensation return-to-work program or other temporary job re-assignments to scan and save MSDS files. Anybody who understands the basics of computer operation can do this part of the job.

Before scanning, each MSDS should be assigned a sequence or control number that uniquely identifies it. For additional quick reference, I suggest affixing a HMIS or other type of chemical hazard info label somewhere on the first page of the MSDS. As much as possible, the sequence number and label should be put in the same place on each one. To maintain consistency, your scanned document should be saved using the sequence number as the file name. The reason for this will become apparent.

The finishing touch Finally, your spreadsheet will be used as your MSDS “Index.” I suggest starting with the following columns to contain data fields:
  • MSDS Sequence Number
  • Chemical Name
  • Trade/Alternate Name
  • Manufacturer
  • Product Type/Use
  • MSDS Issue Date

You may also want to add columns that contain additional data, such as respiratory protection information, recommended PPE, etc. The sky is the limit, because any entry on the spreadsheet can be searched with the program’s “Search” or “Find” command. I suggest letting the MSDS itself do most of the talking, so identity and keyword index data should suffice.

Go with global access Last, embed a hyperlink in each MSDS’s sequence number entry that, when clicked on, will allow immediate access to that MSDS’s image file. You can even embed a link to your new “MSDS Portal” on a Web site or intranet site. When saved in popular, industry-recognized file formats, MSDSs can be accessed remotely from mobile phones, PDAs and other equipment that allows Web access.

One last bit of advice. In the event of a downed network, it is always a good idea to have a hardcopy MSDS library that is maintained in a central location, like the Health and Safety Office. From this point on, the hard work is over. Maintenance is easy. Just scan and log new MSDSs as you receive them.

There you have it — electronic MSDSs on a shoestring budget. From here, you can make your project as fancy or sophisticated as you like, but with these basics in place, you won’t make it any more compliant. You can even go beyond the spreadsheet and use a true database program if you need to include information that would be more suitable to use in that format.

While it’s nice to have all the bells when it comes to spending dollars on regulatory compliance, sometimes it’s just as effective — and considerably less expensive — to just have the whistle.

John Navroth is the safety officer for Snohomish County Government in Washington State. He has 18 years of experience in the safety profession. John can be reached at