North Texas Dentistry Volume 9 Issue 1 2019 ISSUE 1 DE | Page 20

SDS
Part I
compliance
Have a Huge
SDS Book?
Why that’s not a good idea, and
how to make it sleek and useful
by Lee Slaton
Inspecting several hundred dental practices around
the country, I noticed a common feature that creates
extra work for staff – and could delay proper care in
an emergency.
Huge Safety Data Sheets (SDS) books
Manufacturers and distributors take a cover-all-angles
approach (which isn’t in itself a bad thing), and deliver an SDS
(formerly known as MSDS) document for practically every
product — whether it has hazardous properties or not.
As a result, most practices we inspect (at least the first time)
keep SDS documents of every product ever purchased, and have
SDS books that are four to six inches thick. Some have multiple
(4–6” thick) books.
My team of compliance advisors and I helped practices dramat-
ically reduce the size of their SDS books. (In Oregon, we reduced
one practice’s books from two six-inch binders to one two-inch
binder — a much more manageable and usable book to refer to
in an emergency.)
How to simplify your SDS book
Know what’s actually required: SDS documents should be main-
tained for all products classified as hazardous.
How can you tell which products are hazardous, and which
aren’t? The SDS format utilized to meet the Globally Harmo-
nized System of classification makes it much easier to discern
what products are considered hazardous.
How do you know which
SDS documents to keep?
20 NORTH TEXAS DENTISTRY | www.northtexasdentistry.com
1
2
3
1 Keep the ones with hazard pictographs. These are new
images that depict the type of hazard identified. If there’s
no pictograph, check for items 2 and 3.
2 Keep the ones that have a NFPA (National Fire Protec-
tion Association) listing with a number greater than
zero. The old standby, the NFPA diamond, contains four
numbers — one for each type of hazard. If any of them is
greater than zero, the product is considered hazardous.
3 Keep the ones that have an HMIS (Hazardous Materi-
als Identification System) listing with a number
greater than zero. Another old standby, this also contains
four numbers — one for each type of hazard. If any number
is greater than zero, the product is considered hazardous.
Now that you can identify the hazardous products in your prac-
tice and have reduced the size of your SDS book – what’s next?
Create a hazardous chemical inventory list
What is it?
A hazardous chemical inventory list is simply a list of all prod-
ucts your practice has that have hazardous properties.
The hazardous chemical inventory list is an OSHA-required
item — and one of the first things an OSHA inspector will want
to see. I’ve seen practices fined several thousand dollars for not
having one.
It’s also one of the first things emergency responders will want
to see if you have a fire or other emergency in your office,
because it’s the one document that quickly identifies what prod-
ucts are present that could harm them.