What's the best way to organize my Safety Data Sheet (SDS) library?

Safety Data Sheets (SDSs) are produced by chemical manufacturers and must be provided by the company that sells the material. The SDS is updated each time the material changes. Each manufacturer has its own SDS for its products.

The Hazard Communication Standard (HCS) requires the practice leadership to obtain and maintain an SDS on file for each hazardous substance on their hazard materials list. Click here for more information on the hazard material inventory.

The SDSs must be in English (they can be bilingual if necessary) and readily accessible to workers in every work area. Staff members must know how to find and use them. The preferred place to keep your printed SDS library is in the employee break area or in a central location in the hospital. OSHA discourages businesses from keeping the SDS library in the "boss's office;" some staff members may be intimidated by the location, and not use them.

The SDSs should be filed in a systematic way. In our experience, we believe it's best to file them alphabetically by the product name instead of by operational area or category - use a three-ring binder (or two) with tabbed alphabetical dividers. This presents less confusion to the staff member; e. g., is bleach filed under disinfectants or under housekeeping supplies? In those instances where a product is known by several names, you can place a piece of paper in the alphabetical file that directs the reader to the look under the specified name given by the manufacturer (e.g., Lasix® - see furosemide) Make sure to cover the filing system and understanding of SDSs during staff training sessions. The real test of the training's effectiveness is to ask any staff member (try the newest one) to retrieve a specific SDS quickly.

Brand Names?

The SDS must be for the exact product and must be from the manufacturer of the current supply. Some practices will buy several different brands of a product (e.g., alcohol), depending on availability or price. In these instances, it is best to keep several SDSs - one for each brand - in the library, so that whichever brand is purchased, the appropriate information will be available.

When an SDS is needed, first call the distributor who supplied the product. If the distributor or supplier can't get it for you in a reasonable time, request them from the manufacturer. Often the manufacturer will give a phone number directly on the label. When all else fails, send a letter to the manufacturer at the address on the label. When you request SDSs in writing, it's not necessary to send the first request by registered mail; if you get no response, try once more by "return receipt requested." Keep copies of the letter and of the post office receipt. This will demonstrate good faith efforts to obtain the SDSs.     

If you have an SDS for a product that has not changed, but the company name has changed, simply make a note on the SDS reflecting the changed company name; there is no need to get new SDSs each time drug companies merge!

Different Size Bottles or Different Concentrations

The rules do not specifically require different SDSs for different sizes or concentrations of a product, so in the absence of a such a specific requirement, the hospital can do it either way.  

Here's our basic advice...consider different sizes of the same product as a single item. In other words, just maintain one SDS for the 12oz size of a product and the 1 gallon size of the same product. There are a few manufacturers that will prepare different SDSs for different sizes of the same product, but most manufacturers use the same SDS for all size containers.  Unless there is evidence of a different risk with different sizes, it’s OK to use a single one for all sizes.

When it comes to different concentrations, we still consider them the "same product" unless the difference in concentration creates a different hazard. For example, we recommend a single SDS for both the concentrated form of the floor disinfectant and the “diluted, or ready-to-use” form.  However, if a different concentration creates a different hazard in use, treat them as different products.  Although it’s not normal in a veterinary hospital, here's an example from industry: if a company were to use 3% hydrogen peroxide from ABC Chemical Company and they also use 30% hydrogen peroxide from ABC Chemical company, they really need a different SDS for both those products. That's because the dangers of the 30% solution are drastically more sever than for the 3% concentration.

When practical and to keep things simple, we recommend one SDS for all versions of a product from a specific manufacturer unless there is a practical reason to do it otherwise. 

MSDS Directories

There have been several efforts by the distributors and individual companies to produce comprehensive SDS directories. Although these directories may be used for information purposes, they are not replacements for your customized SDS library. It is acceptable to photocopy or "extract" a specific SDS for a product and place it in your SDS library. Don’t fall into a false sense of security by placing the large directory books on the shelf and assuming that all your products are in there and staff members can find them!

Computer Databases & the Internet

It is acceptable to use an on-line source for obtaining the SDSs, but you can't rely exclusively on the internet or an on-line service as the library that you expect employees to use for a couple of reasons:

• 1) No SDS database has exactly every product you need from each and every manufacturer that you use. There are some products in the clinic that are not obtained from the traditional veterinary vendor so it’s unlikely they will be in one of the veterinary-specific SDS databases, so just having access to the database of thousands of SDSs is useless if it doesn't have the one for the product in question.

You certainly don't want to have some SDSs on a computer database and some others on paper. This will only confuse most staff members and make it more unlikely they will find the one they need.

• 2) Although reliability has gotten much better over the years, there's still an issue with the belief that your electronic connection to the internet is not something within your control. And there's the issue of each and every staff member being technically and competently able to get on the service and do a proper search in a database of thousands of SDSs.

The bottom line is that you can't rely on something over which you really don't have control.

However, that doesn’t mean the computer can’t be used to solve the SDS library challenge! When executed properly, we do believe an IN-HOUSE electronic SDS library is perfectly acceptable and in many ways, better than the printed pages in the binders.

Many modern hospitals use an "intranet" to communicate with employees, post information and make their policy manuals readily available. In these practices, since all staff communication is via in-house electronic memos and e-mails, the staff has a level of competency with the system that will allow the indexing of the SDS library so that everyone can find exactly what they need.

SDSs can be scanned as PDF files and are then organized on a specific page of the in-house intranet. Now, a staff member has a full list of all the product SDS in the practice without the clutter of thousands of products not used by the practice!

The practice can't rely on external sources as the complete SDS library when there is no control over the content of those sources or very limited control over access to them; however, an in-house computer source may be just the answer for technologically advances practice.  

 

Did You Know...?

Safety Data Sheets were formerly known as Material Safety Data Sheets or MSDSs.  Although the format of the SDS is slightly different than the MSDS, their purpose is the same.