Date: Sat, 16 Jan 2010 11:29:56 -0500
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: 4 more on MSDS's and DOT
In-Reply-To: <011620101247.23226.4B51B55A00077BED00005ABA22243651029B0A02D29B9B0EBF0A020190010C0E07D20B07900E0B**At_Symbol_Here**>

On Jan 16, 2010, at 7:47 AM, david.iacovone**At_Symbol_Here**ATT.NET wrote:

One thing I would like to see, and many of my colleagues agree, is more uniformity with regards to the layout of MSDSs.  There are content requirements, but to my knowledge, no requirement for format. 

Under the HazCom Standard, 29 CFR 1910.1200, there is no required format.  The required *content* is found in paragraph (g); see http://

OSHA used to recommend their own Form 174, but has encouraged the ANSI format for many years now.  Most manufacturers have moved towards ANSI in recent years, but, again, there is no regulatory mandate for that.  See:

OSHA 174 format: ef/osha.html
ANSI format: ef/ansi.html

But there is light on the horizon!

Once the US adopts the Globally Harmonized System, MSDS's will finally have a set format which basically mirrors the ANSI format.  It will be a number of years before the rule making process results in the biggest change to the HazCom Standard since it was written, and I think that a lots of folks on the list would want to contribute their thoughts during the public comment periods this will entail.  See: f/ghs.html and references therein.

While the "Globally Harmonized System" name suggests that MSDS's around the world will have the same format, there will still be some differences.  The GHS is a model framework only and can't be applied everywhere unchanged.  For example, the GHS calls for complete toxicological and ecological information, including consumer protection, an area that is outside OSHA's authority.  Likewise, GHS requires transportation information that, in the US, falls under DOT.  Nonetheless, it will greatly align MSDS's around the world and make life easier with respect to import/export.

Rob Toreki

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