MSDS's leave a bad taste in my mouth, but I am not going to turn away from a tool that can only increase safety performance. I embrace them for they are a good starting point. I do not dispute that an MSDS, or today an SDS, is a useful tool (especially for the blue collar worker). Sometimes you can even get the flashpoint or autoignition temp or the DOT designations, but I have found inconsistencies and errors over the years. I have also seen MSDS's fail to mention that a substance is listed as a 2B carcinogen. Ask yourself how many times have you had to seek other data after reading the SDS (i.e. HSDB, Toxnet, IRIS, NTP, ACGIH, RTECS, NIOSH, ATSDR, Merck, a peer reviewed article, or some other source). They are often anemic and vague with repetitive catch phrases (i.e. follow all Federal, State and local regulations, Use appropriate personal protective equipment, not fully investigated, etc.). Like many written plans, the SDS is just a document to meet the requirements of the law.

Honestly, I think that the SDS's should be prepared by a single agency and not the manufacturers attorneys. This would make sense, but who would bear that burden? (Perhaps the World Health Organization). At least the SDS has now been standardized. Further, the SDS is for the most part are for the pure substances and when they are for a mixture the proprietary thing gets in the way. I have signed many consent decrees to get the exact ingredients and concentrations of formulations on the basis of exposure and waste determination needs. But as always, I find myself searching the literature for further information - ok, i'm done venting, let me get to the point …

I think that the electronic SDS software is great If it makes laboratory staff use them, and if it works with you inventory program it seems like a no brainer. You should ask - 

Are the employees making good use of the inventory program?

Are employees more likely to refer to SDS's and use them more often in electronic format as opposed to hard copy? 

What are the problems with your current hard copy system? 

Will they have better access to SDS's (i.e. via their "device")?

Are there connectivity issues (i.e. rural areas) ?

Can you track the usage by the users?  

Do you have emergency generators?

For the emergency situations short of apocalypse -  If there is a command center with back-up power then what is the problem with on line system? -nothing!  If the critical network systems are down ( satellites, gas, water, electricity), then I think the last thing anyone will be looking for is an SDS. The spirit of the law is that employees have basic right to know the hazards in the workplace, which is how the SDS is to be used.  I think that many misinterpret the need for SDS's in emergency situations. For that, inventory lists with haz mat categories and locations form your inventory program would probably be of more useful. I think that it is neat your area supervisors bring an SDS binder to the emergency assembly point or emergency room (has a physician ever look at the binder, they use NIH/NLM HSDB). 

Lastly, does anyone know of anyone getting cited for not having an MSDS or SDS? I'd love to know if anyone is on record for failure to maintain MSDS's? ever been fined? or any injury or illness blamed on a lack of MSDS?

Good luck in whatever decision you make. If your institution can afford to pay for the access, it certainly worth prototyping it for a period of time and then evaluating the effectiveness.

Just my $0.02

Be Well,

James Saccardo, CHMM