When is msds too old




















A Material Safety Data Sheet MSDS is a document that contains information on the potential hazards health, fire, reactivity and environmental and how to work safely with the chemical product.

It is an essential starting point for the development of a complete health and safety program. It also contains information on the use, storage, handling and emergency procedures all related to the hazards of the material. The MSDS contains much more information about the material than the label. MSDSs are prepared by the supplier or manufacturer of the material. It is intended to tell what the hazards of the product are, how to use the product safely, what to expect if the recommendations are not followed, what to do if accidents occur, how to recognize symptoms of overexposure, and what to do if such incidents occur.

These categories are specified in the Controlled Products Regulations and include:. Yes, as long as two conditions are met. All headings and subheadings that are on the MSDS must be addressed by providing the required information or by stating that the information is not available or not applicable, whichever is appropriate.

Radioactive materials are exempt from coverage under the HCS if the only hazard they pose is radiological. However, if the material also possesses physical or health hazard , then an SDS is required. See Occupational safety and health guideline for uranium and insoluble compounds , for example.

Biological hazards biohazards, biohazardous materials are exempt from coverage under the HCS if the only hazard they pose is biological. Examples of biohazards include microbes, anthrax , vaccines, and cell cultures. According to the first OSHA interpretation listed below, " Office workers who encounter hazardous chemicals only in isolated instances are not covered by the rule. The Occupational Safety and Health Administration OSHA considers most office products such as pens, pencils, adhesive tape to be exempt under the provisions of the rule, either as articles or as consumer products.

For example, OSHA has previously stated that intermittent or occasional use of a copying machine does not result in coverage under the rule. However, if an employee handles the chemicals to service the machine, or operates it for long periods of time, then the program would have to be applied.

For example, if an employee uses a solvent to clean a typewriter once a year, that situation does not require an SDS. But if the employee cleans typewriters every day as a repair person, then an SDS is required. There will likely be occasions when someone will ask for an SDS when one is not required or demand a written statement that no SDS is required.

Section G. Nonetheless, some downstream clients may still insist on an SDS in cases where one is not required. If you encounter someone who will not accept a verbal assurance, OSHA has suggested providing a written statement such as " This product is not considered to be or to contain hazardous chemicals based on evaluations made by our company under the OSHA Hazard Communication Standard, 29 CFR For items that are specifically exempted from coverage under the Standard, your statement should reflect the specific exemption s and the specific paragraph s of the standard which applies.

On the other hand, you may receive an SDS for something that is truly not hazardous. For example, Amerex has an SDS for deionized water used in water mist fire extinguishers. However, your attorney may advise you to keep it anyway just to be sure. As mentioned previously and discussed below , manufacturers and distributors are under no OSHA obligation to supply SDS's to consumers. We encourage manufacturers to make SDS's freely available to everyone, but suggest that the sheets carry a notice explaining that SDS's are meant for occupational use, not consumer use.

For example, the original manufacturer or importer, Employer A, must create an SDS for any hazardous chemical that they produce. In other words, the information flows:. Note: While this flow diagram indicates "Employer C", an upstream supplier might ship a material to more than one physical location for a particular downstream employer.

In such cases, the SDS must be sent to each location where the material is used, not simply the employer's main office.

See Responsibility of chemical manufacturers and importers to provide MSDSs to one or more establishments owned and managed by same employer.

Your primary obligation in supplying MSDSs is to your direct customers, that is, your distributors. You must provide a copy of the MSDS with the first shipment to each of your direct customers, and, if the MSDS for one of your products is updated, you must send the updated MSDS with the next shipment of the product to that direct customer.

Your distributors are, in turn, responsible for supplying a copy of the MSDS with the first shipment to each of their direct customers, and so on However, because this chain of information transmission through the distributor can sometimes be broken, OSHA has added the requirement that manufacturers must provide a copy of the MSDS to other "downstream" employers upon request.

Your "FAX-on-demand" system can be used to fulfill this requirement. Please refer to revised language in paragraphs g 6 and g 7 of the standard for additional clarification on requirements for providing MSDSs. In general, if you need an SDS, you should get it from your "upstream" supplier.

If that is not possible, then the manufacturer must supply one on request as long as you are an employer that requires an SDS under the Hazard Communication Standard. See also: Manufacturer and employer responsibilities when providing MSDSs electronically for more on downstream flow and manufacturer responsibilities.

Consumers : As stated previously , many manufacturers or distributors are happy to give an SDS to anyone who asks but they are under no OSHA obligation to distribute these to consumers. See this OSHA interpretation letter and the downstream flow entry above for more information about how SDS's are supposed to be distributed.

Although most contractors will gladly provide an SDS, they are under no regulatory obligation to do so. If you are certain that the material meets the OSHA definition of hazardous then the contractor is required to have an SDS for his employee's use. If not, he is in violation of OSHA regulations.

Just the threat of reporting the contractor to OSHA for willful non-compliance is probably enough to change his mind. Alternatively, a letter from an attorney might work, too. If you have no luck with the contractor, try the original manufacturer's web site or toll-free number. But if you want to know for certain whether there are potentially hazardous fumes in your house, have the air professionally tested.

Some products, like pesticides and consumer products, are exempt from WHMIS as they are regulated under other legislation. A comprehensive chemical safety program in the workplace should ensure employees are trained on the hazards of all products they may be exposed to in the workplace no matter if the products fall under WHMIS or not.

Get a free minute video every month on chemical hazards and how to protect yourself. Our monthly newsletter is a great resource for toolbox talks. Get access to our blogs, webinars and resources on chemical management. January 24, Ref: The rules for the safe use of chemicals at workplace It is not clear what kind of information triggers the need to update SDSs.

It is not clear whether all previous recipients should be provided with the updated SDSs either. Korea requires suppliers to update SDSs and provide updated versions to recipients when there are any changes made to the following sections in SDSs.

It means that you may need to review your SDSs every 3 years to make sure that they are always compliant with the latest hazard communication requirements. Ref: Korea MoEL notice A manufacturer, importer, supplier, or employer shall check the accuracy of a Safety Data Sheet SDS based on the actual circumstances and update it as needed.

A Safety Data Sheet shall be reviewed at least every 3 years.



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