Use of Mini-SDSs
Through ChemWatch we have access to mini-SDS which is a 1-page summary of the full 16-pt SDS. Does having these readily on hand satisfy the requirements to "have a current SDS for each hazardous substance you use, handle, manufacture or store" as per the WorkSafe guidance on Working safely with hazardous substances?
Users will have full access to the ChemWatch portal if they
the full SDS.
I've attached an example.
Wurth Brake Clean - Mini SDS
Regarding the statutory requirement for providing information to workers the regulations include for "...or a condensed version of the key information from the safety data sheet (for example, a product safety card)..." or similar statement.
Still have to have obtain the full SDS when "first supplied or after it has been amended though.
R2.11 Hazardous Substances Regulations
Para 1 of Section 2.11 states "must obtain the current safety data sheet for a hazardous substance from the manufacturer, importer, or supplier of the hazardous substance".
Chemwatch don't appear to fall into any of the three categories. Also the mini SDS is copyright to Chematch indicating they have issued it and while the info may be correct, should anything go pear shaped you as the PCBU may be liable if the info is incorrect (due diligence is missing
If the information was produced at the source rather than by an intermediary, it would be reliable. The only method of determining whether the information in mini SDS is correct would be contact the manufacturer, importer, or supplier.
There are H&S and legal implications as it's not only a risk for workers to rely on the info in the condensed SDS but also a risk for the manufacturer, importer, or supplier to have their SDS condensed by a third party.
In the end, only you can determine what your risk appetite is.
Technically both Matt and Keith are correct Brendon, though 2.11 Clause 3 allows for the use of a condensed version of the key information.
Keith's closing statement is pertinent, but you are dealing with a North American company, where getting it wrong is a recipe for winding up in court defending a multi million dollar lawsuit and in ChemWatch's blurb, they state;
Alerts and Reports
Receive email notifications about the status of your SDS- these updates include a ‘redness report’ for quick identification of exact changes in the SDS so you can compare to the previous version and update your safety procedures and any physical SDS folders accordingly".
So it would seem likely that their service could reasonably relied upon, and I can see the attraction of outsourcing this. I also like the way they present the information, and I assume they can supply versions in other languages if required (and depending on the make up of your companies work force), make your call but consider Keith's caveat.
Also, if using condensed versions, WorkSafe suggest what data should be contained in them (in their SDS - Quick Guide).
Yes we use mini SDSs for our 20 or so most used substances. These are easier for staff to read and understand.
Mini sds are great for point of use. No one wades through a 14 pager before using a substance. Having the full system readily available (soft copy is ok) satisfies the requirements
Yup - mini SDS' all the way as a quick reference.
Full SDS' on hand for when things go pear-shaped.
If the issue date is the issue date of the full SDS and not the condensed version then this would continue to assist to ensure SDS are less than 5 years old as required by legislation.
Before Product Safety Cards became 'a thing', I was training factory workers in quality improvement and H&S. They worked with a range of chemicals, so it was important that they understood the hazards, risks and controls. It didn't help that English was not their first language, and they were, as one might reasonably expect from unskilled labour, not particularly sophisticated or extensively educated.
After a very, very successful experience of providing workers with tailored literacy and numeracy training in partnership with Adult Reading and Literacy Association (ARLA), and having completed more training myself in Accelerated Learning and Neuro-Linguistic Programming, I had an epiphany while trying to teach them to navigate their safety data sheets. I gave a copy of one SDS to two of the more literate workers and asked them to highlight all the words they didn't understand or were not sure of. And as you might expect, the documents came back covered in highlighter! So we took a step back and asked ourselves what was the actual purpose / intent of this training. We concluded that the key aim was NOT actually about being able to read our safety data sheets; the most important thing was for them to have important information they could easily use if there was an emergency.
So we simplified the language, cut out all the information that was not immediately relevant to them and their work, and we illustrated the documents wherever possible for clarity and ease of use. Instead of "Identification", we used a heading "What it looks like". Instead of 'nasal passages' (they told me when they asked the engineer what that meant, he told them something rather more rude....!!), we just said "nose".
Safety data sheets have their place, but it helps to remember they are written BY and FOR technical people. People on the factory floor need information in a form that they can use. When you remember that people are generally doing the best they can with what they know (if they knew better, they would DO better), one of the most useful things managers and leaders can do is to identify all the obstacles and work toward removing them. Not only is that approach a lot more effective; it also creates trust, rapport and engagement all along the way.
This example is one of the many small pieces of great leadership from their management team that ultimately led to productivity improvements so massive that it caught the attention of corporate managers, who kept coming to the site to find out how it was done. Unfortunately, most of those corporate managers just wanted a quick fix and never really grasped the long, dedicated process undertaken by the site management team - I feel very fortunate to have had the opportunity to work alongside them and contribute to developing their people.
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