Date: Wed, 23 Feb 2011 16:09:39 -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: Mary Cavanaugh <cavanaughmm**At_Symbol_Here**APPSTATE.EDU>
Subject: Re: MSDS Retention
In-Reply-To: <OF9B441629.38572AE5-ON86257840.0057E536-85257840.005863A1**At_Symbol_Here**>

Mary Ellen is right.  And since it’s hard to know what employee was exposed when, we just keep ours forever, archiving them eventually.  Soon we hope to go digital which will at least cut way down on the paper.

From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Mary Ellen Abel
Sent: Wednesday, February 23, 2011 11:05 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] MSDS Retention

It is my understanding that the '30 years' refers to the date of the last potential exposure, not the data that the 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 have been screening MSDSs for products used in our underground mine long before 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, Patricia" <Patricia.Peifer**At_Symbol_Here**WESTPHARMA.COM>
Sent by: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**>

02/23/2011 09:17 AM

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[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

Find West on Twitter and LinkedIn.

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