To the typical employee in the death care industry, OSHA is about annual training. To the owner of the business, it is about an annual fee. To the regulatory consultant, it is about developing and presenting safety training, trying to make it more simple, and trying to accomplish the requirements without turning the workplace over. If everyone does their job, then there is a safety benefit, although it is not always apparent.

  Two years ago, OSHA adopted a Global Harmonized System of Chemical Classification. At its core, businesses gave up the Material Safety Data Sheet (MSDS) and replaced it with a Safety Data Sheet. They had their reasons and I don’t question them. To our customers, it meant replacing a two page MSDS with an 11 page SDS. That was a real problem. If a large funeral home used one hundred embalming products and a dozen industrial products for their car wash, flower shop and monument shop, the 1100 page SDS binder would approach the size of an unabridged dictionary.

  We felt that called for a better idea. To me, it meant going to a digital SDS system. I then checked to see if OSHA would allow our customers to store SDS pages on a digital system. They would if the employees knew how to access them. I emailed or sent a thumb drive of the digital program my customers. Case closed? Not exactly.

  I completed this project two years ago, my SDS problem was solved. It even brought me calls and emails thanking me for solving the problem. The method I used is what prompted all the nice compliments. The method I used turned out to be a problem. It turned out to be the reason I had to scrap that system and come up with a Plan B. What was wrong with Plan A?

  In my initial plan, I created a document folder for every major supplier. If the major supplier categorized products in multiple categories, I used folders and sub-folders. Then I made a PDF file for every product. All in all, it was thousands of products and it easily fit on a 2-gigabyte thumb drive. Contrast that thumb drive with an 1100 page SDS file and you can understand why my customers were pleased. You can understand why we were pleased. But it was all premature.

  A few months ago, I had a computer tech out to the office for some routine maintenance. I was explaining the purpose of the program and he asked me this question. What happens when suppliers add new products? How are they captured? The answer was they were not. Try as I might, I could see that the program had a fatal flaw. The tech and I worked out a Plan B that would allow customers to access all existing products as well as new products as they were introduced.

  We are in the process of distributing SDS 2.0 to our customers. We do that via email or by mailing a thumb drive with the program on it. Instead of thousands of PDF files, there are none. Instead, there are links to all the major suppliers SDS page. Once there, they can navigate to whatever product they want to access. Each supplier maintains the list and adds new SDS’s as products are introduced.

  Sometimes it feels like we are going in circles. Sometimes we do but that is okay if it ends up giving the customer a better mousetrap. For now, I think we have. There are two caveats. Customers need to ensure that employees know how to access and navigate the program. When they cannot, then print out SDS pages for the products to which that employee is exposed. You are not required to print out the entire SDS inventory.