Updating your collection of Safety Data Sheets (SDSs) is time consuming, never ending and of limited value – like Sisyphus rolling the boulder up the hill in Greek mythology.

Why is it so Hard?

A supplier is only required to provide you with an SDS when you make a purchase.  This impacts you in three distinct ways:

• If you are using product from your inventory and the SDS changes the Supplier is not required to let you know of the change.
• If you order replacement product and you receive an SDS, you will not know if you need to update the version in your system without comparing the old and new versions.
• If you get an SDS from a supplier today it could be updated next week without any communication informing you of that change.

In practice this means keeping all your SDSs up-to-date is impossible. No organization, no individual and no SDS document management provider can do it.

4 Facts to Consider When Updating Your SDSs

1. 90% of SDSs are available on the Supplier’s website
2. 75% of SDSs > 5 years old have the same hazards as the updated sheet
3. 30% of SDSs do not have any WHMIS hazards
4. 20% of SDSs in a collection are duplicates or are no longer required

Source – Rillea Technologies Inc. based on data analysis of client SDS collections.

Don’t Let Perfection Get in the Way of Good

Based on our analysis we recommend you use the following criteria to identify which sheets to update:

1. Look for replacements for old MSDSs or sheets with errors as your first priority.
2. Only look for updates to SDSs that are:
   1. Over 5 years old
   2. Still in use
   3. Have WHMIS hazards identified on the existing SDS
3. Focus on SDSs were the supplier has them available on their website – this will provide the biggest bang for your time. Contacting suppliers and asking them to send sheets is time consuming and our experience says only 30% effective.
4. Document your findings and do not look again for an updated SDS for at least 1 year.

What About the 3 Year Rule?

The old version of WHMIS (referred to as WHMIS 1988) required suppliers to review and update MSDSs every 3 years. With WHMIS 2015 this is no longer the case. An SDS from 2015 may still be correct and the most current version.

Like suppliers, employers in most jurisdictions in Canada (ie Ontario) are not required to update an SDS simply because it is more than 3 years old. That said, in some jurisdictions (ie federally regulated, British Columbia, Nunavut, Yukon, Northwest Territories and Nova Scotia) employers are required to try and obtain new SDSs every 3 years. If an SDS is more than 3 years old, the Government of Canada requires the following:

“If a supplier SDS for a hazardous product found in the work place is 3 years old or more, the employer shall if practicable, obtain a current SDS from the supplier.

If it is not possible for an employer to obtain a current SDS, the employer shall update the hazard information on the most recent SDS received, on the basis of the ingredients disclosed on that SDS and any significant new data of which the employer is aware.”

The challenge with this requirement is that the current SDS you obtain from the supplier maybe more than 3 years old.  In this scenario, documentation of your efforts is even more important. If you work in a jurisdiction that still utilizes the 3 year rule you may want to adjust the process above to sheets over 3 rather than 5 years old.

Where Can I Learn More About SDS Management?

In addition to updating SDSs, SDS Management includes organizing where your SDSs are stored, how employees access them and what steps you take to make the information in your SDSs relevant, easy to understand and helpful in protecting employees in the workplace. More information is available in our  Guide to SDS Management.

If you need a next generation SDS Management system that goes beyond managing SDSs to extracting and prioritizing data from SDSs and associated regulations to help you manage chemical safety, contact us.