Easy (and Compliant!) SDS Organization

By Gracie Hogue, BM

One of the things we’ve noticed over the years in visiting different practice’s is the state of their SDS binder. We often see what we refer to as “Frankenbinders,” which have chunks missing, pieces of unrelated materials added, and an overall disarray of pages. When you look at it, it gives you feelings of dread and procrastination and you definitely wouldn’t want OSHA to see it if they were to drop by unannounced.

We have two ways we can help you with this:

You can read this article and follow the simple steps to get your binder back in order,

OR

You can subscribe to our SDS Online program where we keep your SDS organized for you online via a search engine that you can access 24/7. See end of this article for more info!

How to get your binder back in order manually:

1. Make sure you have all the SDS you need (and don’t waste your time on getting SDS you don’t need!). Safety Data Sheets are for the products you use in your practice that have chemical properties as their base. For the most part, SDS is specific to powders, liquids, pastes, gasses, semi-solids, and anything that has potentially hazardous chemicals or could cause harm via contact or that is dissolvable or digestible. Items that don’t fit in this category would be instruments or PPE such as sutures, gloves, masks, crowns, scalpels, etc. Most of these items don’t even have SDS published for them, so it would be a waste of your time to look for SDS for these types of items.Time-saver tip: you don’t need SDS for some products if they’re being used as household items. For example, if you’re using Windex only to clean the windows when patients are not in the building, you don’t need to obtain SDS for that product.

How do you get the SDS you need? Most products now have their SDS on their website, or you can request a copy to be sent to you via the customer service contact info on the product’s container label. Make sure that when you request an SDS to be sent to you that you include the full name of the product and any product’s specification numbers so you have the correct SDS. “Close enough” does not count with OSHA.

2. Once you’ve got all your SDS obtained, OSHA recommends that you organize the pages alphabetically by product name. We’ve heard from some clients that they don’t like to do this because they want to group all the types of products together instead. But OSHA strongly recommends that it be alphabetical. If you want to make it easier to find certain products in your binder, you can get color-coded sticky tabs for certain types of products (blue for prophy pastes, orange for epinephrine injections, green for sanitary wipes, etc.). This method can make your hard copy search go much more quickly. From OSHA’s Hazard Communication: Hazard Classification Guidance for Manufacturers, Importers, and Employers:“If a chemical meets the definition of hazardous chemical, as defined by the Hazard Communication Standard, and the hazardous chemical is one that requires classification, then it must be included on the hazardous chemicals list. OSHA recommends that the list be alphabetized to ease retrieval, stored so that it may be accessed easily, and archived in a secure location for future use.”
3. Highlight the most important sections in the SDS. The most important sections in your SDS are sections 2, 3, 4, 6, 7, and 8.

• Section 2: Hazards Identification: This is where you’ll see what kind of damage the chemicals in this product can do and how toxic they are, such as “Serious eye damage/irritation.” This section lets you know how to respond with certain types of chemical contact.
• Section 3: Composition/Ingredients: OSHA wants to see a chemical index in your SDS binder, so highlighting this section makes this stand out as a part of your chemical index.
• Section 4: First Aid Measures: This section covers what to do if the product is inhaled, ingested, makes skin and/or eye contact, etc.
• Section 6: Release Measures: This is how to dispose of the product properly. Not everything can just go in the trash or be flushed down the toilet.
• Section 7: Handling and Storage: Some products need to be refrigerated, or some products need to be shaken before use or handled with care. This section tells you how to store and handle the product.
• Section 8: Personal Protection: This section covers what PPE you need to be wearing when handling the product.

4. By keeping your SDS organized alphabetically and highlighting Section 3 of each SDS, you automatically maintain an organized Chemical Inventory which OSHA requires. From OSHA’s Hazard Communication: Hazard Classification Guidance for Manufacturers, Importers, and Employers:“The Hazard Communication Standard requires employers to maintain a list of hazardous chemicals present in the workplace as a part of the Written Hazard Communication Program (29 CFR 1910.1200(e)). The purpose of having a list of hazardous chemicals at your facility is to document those chemicals used or stored at the facility. Not only will the list facilitate the identification of the hazards presented by the hazardous chemicals at the facility or in a given work area, a complete list of chemicals also may help identify the information you already have on the chemicals or other ingredients used in production of the final product. Since safety data sheets are required for the chemicals you receive, this may be a good place to start the list. The hazards profile developed for each chemical (discussed above) also may be useful to determine which of the chemicals in the facility or work area are considered hazardous.”
5. When no longer using a product, write the date (month, day, year) of final use of that product at the top right corner on SDS. Once you have ceased using a product, place it in a separate binder marked “Archived SDS” or “SDS: Products No Longer In Use.” OSHA requires that SDS for a product be retained/kept for 30 years after the final use of that product (29 CFR 1910.1020(d)(1)(ii)(B)). The reason for this is that SDS are considered to be employee exposure records.If you have the date of the product’s final use on the SDS, you will know how long to retain it. If the practice decides that they want to use that product again, simply white out the date written and place it back in the “In Use/Current” SDS binder.

If you’d rather save time and paper in the long run, we can organize your SDS for you! Our SDS Online Subscription program is programmed so you just send us a list of your products and their manufacturers, and we take it from there. You have 24/7 online access to your SDS through an eBinder search engine, and send you an annual chemical inventory list annually so your records are neat and tidy.

If you’re interested in the SDS Online program, please email [email protected] or call us at (931) 232-7738.