The SDS update challenge

Keeping safety data sheets updated is a task that can frustrate and exhaust any workplace safety professional.

The Workplace Hazardous Materials Information System (WHMIS) requires employers to ensure that employees have access to up-to-date Safety Data Sheets (SDSs) for all hazardous products in your workplace.

SDSs are an important workplace health and safety tool: they provide a detailed description of a chemical product’s hazards, including possible health effects related to short- and long-term exposures. They also provide additional information on safe use, handling, storage and disposal procedures. This information is essential to protect workers and to reduce the prevalence of occupational disease in Canada.

WHMIS requirements for safety data sheet updates

Ontario Regulation 860 (WHMIS) outlines the requirements for updating safety data sheets as follows:

(1) An employer who receives a hazardous product from a supplier for use, storage or handling at a workplace shall obtain a supplier safety data sheet for the hazardous product from the supplier unless the supplier is exempted under the Hazardous Products Regulations (Canada) from providing a safety data sheet for the hazardous product. O. Reg. 168/16, s. 11.

(2)  An employer shall update a supplier safety data sheet obtained under subsection (1) as soon as practicable after significant new data about the product is provided by the supplier or otherwise becomes available to the employer. O. Reg. 168/16, s. 11.

The Canadian Centre for Occupational Health and Safety further explains that “an SDS must be updated when there is new information that changes how the hazardous product is classified, or when there are changes to the way you will handle or store or protect yourself from the hazards of the product.”

While Canada’s Hazardous Products Regulations require suppliers to update their SDSs only if new information becomes available, it is important to note that each provincial/territorial jurisdiction in Canada regulates occupational health and safety.

See our SDS RiskAssist Guide to SDS Management to understand the requirements for the jurisdiction(s) that your business operates in.

Practical tips for updating your SDS collection

Keeping safety data sheets updated is not easy; in fact, it’s impossible to ensure your SDS collection is 100% up to date at all times, given that the average workplace has 120 chemicals on site.

A supplier is only required to provide you with an SDS when you make a purchase. If the SDS for a product in your inventory changes, the supplier is not required to let you know. And if you re-order a product and you receive an SDS, you’ll need to compare old and new versions to see if there are changes.

SDS RiskAssist gathers data from every SDS and every client. That allows us to look at information in many different ways. We’ve reviewed more than 45,000 safety data sheets in 300+ workplaces, which has given us important insights into the best way to tackle the problem of keeping safety data sheets updated:

• In an unreviewed collection 5% of documents are duplicates
• Another 10 % of sheets are obsolete, discontinued or no longer required
• The average difference in dates between an older and newer version of an SDS is 3.3 years
• Only 17% of reviewed SDSs have newer versions with significant differences in hazards. Only 17% of SDSs actually needed to be replaced
• The percentage of sheets which required replacement varied by supplier from 0-75%

5 steps to update your SDS collection:

Based on SDS RiskAssist data, we recommend the following 5-step process to identify and update the safety data sheets in your collection:

1. Eliminate any duplicates
2. Check if still using all MSDSs and any SDSs over 7 years old
3. Update largest suppliers first
4. Ensure that any information attached to the existing document (i.e., where used) is assigned to the new SDS
5. Remove the replaced sheet from your active collection so as not to create confusion amongst workers

How SDS RiskAssist technology solves the problem of updating safety data sheets

SDS RiskAssist uses digital technology to automatically extract critical information in your safety data sheets and summarize it in actionable ways:

• Quickly identify potential duplicate SDSs in your collection and merge them into a single entry at the click of a button
• Rapidly sort existing SDS sheets to find potential obsolete documents
• Consolidate all brands, subsidiaries and affiliated companies under the parent supplier’s names
• Know when to update your SDSs: we provide links to supplier webpages (available for 85% of SDSs in a typical collection) with target replacement dates based on historical data
• Automatically replace SDSs using the supplier URLs or pdfs, which also copies attached data over and archives older SDSs