Date: Wed, 23 Feb 2011 15:30:42 -0600
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: "Long, Don" <don.long**At_Symbol_Here**WGINT.COM>
Subject: Re: MSDS Retention

Ohio falls under the Federal OSHA, so I'm sure  ;that facility is an "OSHA regulated" facility.
As far as maintaining MSDSs, it's not that difficul t to maintain them electronically. We are supposed to be in the business of taking care of folks. I don't understand the conflict here. We are already required to maintain medical records of employees employed more than 1 year for "the duration of employment pl us 30 years". It stands to reason that the MSDSs would follow the same reasoning.
I know when the Feds audit us (Army, CDC, OSHA, etc ) their response is that if it's been used then we better have an MSDS. In the Haz-Com exerpt below, it seems to make it clear that we "shall maintain copies of any MSDSs that are re ceived with incoming shipments...".


"Employers shall maintain copies of an y material safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals, shall obtain a material safety data sheet as soon as possible for sealed c ontainers of hazardous chemicals received without a material safety data sh eet if an employee requests the material safety data sheet, and shall ensur e that the material safety data sheets are readily accessible during each work shift to employees when the y are in their work area(s);"

Just some thoughts....


Don A. Long
Southwest Research Institute Laboratory
Pine Bluff Chemical Agent Disposal Facility
PO Box 2013 0
White Hall, AR 71612
870-541-493 0

From: DCHAS-L Discussion List [mail to:DCHAS-L**At_Symbol_Here**] On Behalf Of Mary Ellen Abel
Sent: Wednesday, February 23, 2011 10:05 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] MSDS Retention

It is my understanding that the '30 ye ars' refers to the date of the last potential exposure, not the data that t he MSDS was received.  So that 30 years might actually be 45 years, if that individual used it for a period beyond its first use.  Although I am not in an OSHA regulated facility, we h ave been screening MSDSs for products used in our underground mine long bef ore Haz Com was ever developed.

Mary Ellen Abel
Quality Assurance & Environmental Manager
Morton Salt
P.O. Box 428
Grand River, OH 44045-0428
phone:  440-639-4279
fax:  440-639-4269
cell:  440-479-9022

"Peifer, Pat ricia" <Patricia.Peifer**At_Symbol_Here**WESTPHARMA.COM>
Sent by: DCHAS-L Discussion List <D CHAS-L**At_Symbol_Here**>

02/23/2011 09:17 AM
Please respond t o
DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**>

[DCHAS-L] MSDS Retention

A debate has come up within our organizat ion 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 expo sed to a chemical and said we did not provide them with adequate informatio n.   I planned on keeping them for thirty years.  
Others in my organization feel I may be w asting my time.  They feel I should be throwing out older versions and only retaining the latest copy particularly if the revisions were not sign ificant.   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

Find West on Twitter and LinkedIn.

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