f the employee’s work area includes the area where the MSDSs can be obtained, then maintaining MSDSs on a computer would be in compliance. If the MSDSs can be accessed only out of the employee’s work area(s), then the employer would be out of compliance with paragraphs (g)(8) or (g)(9) [of the Hazard Communication Standard].
Reference Interpretation and Compliance Letters:
- Maintaining MSDSs on a computer data base. [1/13/86]
- The acceptability of your “FAX-on-demand” system for providing copies of material safety data sheets (MSDS). [08/31/94]
- Interpretation on whether “an equivalent electronic information system” could be used in lieu of MSDSs to satisfy the HCS. [07/06/90]
- Using the telephone to back-up electronic access to MSDSs. [10/13/98]
October 2018
Tags: HAZCOM, OSHA
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