Compliance with safety regulations pertaining to MSDS management is every employer’s responsibility. Although an employer may not be the one who generates a new safety data sheet, all companies must make the sharing of safety data an integral part of their MSDS programs. Through the use of a downstream flow concept, companies can provide effective MSDS services and ensure that everyone handling hazardous chemicals has the safety information they need.
What Is Downstream Flow?
Concerning MSDS programs, downstream flow relates to the idea that safety data sheets must travel with hazardous chemicals “downstream,” to reach those companies using such substances. There are two main parts to this process: the creation of safety data and its distribution. Information distribution starts at the upstream supplier and travels downstream as substances are sold and used. In this manner, the information is made available to all companies and their employees that work with a hazardous chemical.
Who Is Responsible for What?
When a new chemical or compound is created, the company that does so is responsible for generating a new OSHA safety data sheet in compliance with current MSDS management standards. Once that sheet is generated, the manufacturer must then distribute the information. It must be provided first to employees and then to any other company that purchases the substance, whether for internal use or for distribution. Secondary customers that receive SDS from the manufacturer must then do the same, making SDS available to all employees and then to commercial customers who may purchase the chemical.
Every company that receives a hazardous chemical from a manufacturer or upstream supplier manufacturer should receive with it the required SDS. They must, in turn, pass that same information on to all employees and any commercial customers that subsequently receive it.
Required Distribution of MSDS Information
OSHA’s Hazard Communication Standard (HCS) requires that manufacturers and upstream suppliers provide SDS to downstream users either in print or electronically. Companies can ship hard copies with shipments, fax copies, or they can email SDS to customers if so approved. Along with this initial distribution of safety information, it is also a requirement that manufacturers provide updates to any SDS as they are released so that customers always have access to the most current safety information. In addition, OSHA also requires that upstream MSDS services send SDS to all customer locations where the chemical is shipped, not just to a main company office or central location.
All companies, whether shipping or receiving hazardous chemicals, are required to make SDS available to their employees. This information must be printed and stored in a central location with other hazard training material or be readily accessible electronically by all employees.
Effective MSDS management must be regarded as an essential part of every company’s safety communication program. It is the employer’s responsibility to create MSDS programs that provide employees and commercial customers with the SDS needed for safe handling of hazardous chemicals. Passing this information via organized MSDS services is a responsibility of all upstream suppliers and required for OSHA compliance.