Can safety data sheets (SDSs) be kept on a computer to meet the accessibility requirements of the Hazard Communication (HazCom) standard?

Yes. OSHA 1910.1200(g)(8) says, “Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options." According to OSHA, if the employer is maintaining SDSs electronically:

• All employees must have immediate, adequate computer access in their work area, with no restrictions;
• There must be a backup procedure or system (e.g., paper or another electronic system) in place in case the computer is not functioning;
• The employees must be trained on how to access the SDSs (both on the computer and the backup procedure or system); and
• There must be a procedure or system in place to ensure that employees can receive a hard copy if so desired and in cases of emergency (which must be transmitted to medical personnel). It is not acceptable to only transmit the information verbally.

For example, the following would not be compliant:

• Employees must perform an Internet search to view or obtain the SDS,
• The SDSs can only be accessed outside of the employee’s work area(s),
• The SDSs can only be accessed through a website that the employee has not been trained in or does not have a username or password,
• Access is only in a room locked at certain times when employees may need to access the sheets,
• Employees are required to ask for the SDS,
• There is no backup procedure or system in place, or
• There is no procedure or system to ensure employees receive a hard copy if desired or in case of emergency.