Date: Wed, 23 Feb 2011 10:27:12 -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: Ben Ruekberg <bruekberg**At_Symbol_Here**CHM.URI.EDU>
Subject: Re: MSDS Retention
In-Reply-To: <28F93920539A4F4AB4FE1199003CAD2F032F2D70**At_Symbol_Here**>

It is my impression that you are correct.  Not only can you show that you had the MSDSs at the time of someone’s alleged exposure, but (perhaps more importantly) you can document that any later-discovered hazards were not known at the time.  Consider phenolphthalein, formerly in Ex-Lax, now a carcinogen.  Similarly, chloroform used to be in toothpaste (for that tingly feeling).

From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Peifer, Patricia
Sent: Wednesday, February 23, 2011 9:06 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] MSDS Retention

A debate has come up within our organization concerning the retention of MSDSs.  I have been saving old copies of MSDSs for which new revisions have been issued.   My understanding is that this would be proof that we did have the MSDS on file if an employee claimed twenty years later that they were exposed to a chemical and said we did not provide them with adequate information.   I planned on keeping them for thirty years. 


Others in my organization feel I may be wasting my time.  They feel I should be throwing out older versions and only retaining the latest copy particularly if the revisions were not significant.   They do agree however, that I should be keeping old MSDSs for chemicals for which we discontinue use. 


Any thoughts?  Thank you, everyone. 


Pat Peifer

Health Safety and Training Team Leader

West Pharmaceutical Services



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