Date: Thu, 24 Feb 2011 18:09:02 -0500
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From: "Secretary, ACS Division of Chemical Health and Safety"

Subject: 6 Re: [DCHAS-L] MSDS Retention

From: "Alnajjar, Mikhail S" <ms.alnajjar**At_Symbol_Here**>

Date: February 24, 2011 11:46:55 AM EST
Subject: RE: [DCHAS-L] MSDS Retention

Good point.  Somehow the 30 years makes us feel safe and protected!!! My other two cents.  But, it is required that we have to follow the codes.



From: wdwatt**At_Symbol_Here**
Date: February 24, 2011 1:18:37 PM EST
Subject: Re: [DCHAS-L] MSDS Retention

The intent of the OHSA regulation is to keep track of worker exposures. The MSDS is considered to be an exposure record. Therefore you must retain it for employment plus 30 years.
Bill Watt
Wayne State U.


From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] On Behalf Of Mary Ellen Abel 
Sent: Wednesday, February 23, 2011 10:05 AM 
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 

From: ACTSNYC**At_Symbol_Here**
Date: February 24, 2011 12:56:46 PM EST
Subject: Re: [DCHAS-L] MSDS Retention

>I agree - I see a lot of =93kits=94 in biology and frankly the MSDS is useless!
>It is practically impossible to know what is in these products and how to dispose of the waste.
>I am keeping the MSDS though!!

Good.  You've done due dilligance and it is the manufacturer that becomes the Defendant if something goes wrong.   Monona


From: kauletta**At_Symbol_Here**< /a>
Date: February 24, 2011 2:52:25 PM EST
Subject: Re: [DCHAS-L] MSDS Retention

All of your suggestions as to WHY retention of MSDSs are valid and useful (may be needed to justify health claims; regulatory requirement, etc). BUT - as the MSDS point person for our large university who is responsible for 19,000++++ MSDSs, I can tell you that it is a difficult and daunting task. Where do I store them? My "archive space" was just demolished to make room for more classrooms. Digitize/scan them? Who is going to scan that many pieces of paper? Who is going to pay for that? What about in 10 years when that technology is no longer valid (I have a few zip discs of MSDSs I can no longer open!) Keep a running inventory of what product is being used in each lab by person? Come visit & tell me it can be done! 

I've got BOXES of MSDSs stored - yes I've met the regulatory requirement. 

Kim Auletta
Lab Safety Specialist
EH&S    Z=6200
Stony Brook University
kauletta**At_Symbol_Here**< /a>
FAX: 631-632-9683
EH&S Web site: lab/


From: ACTSNYC**At_Symbol_Here**
Date: February 24, 2011 12:53:40 PM EST
Subject: Re: [DCHAS-L] MSDS Retention

Good point Edward.  When we do litigation, we try to get MSDSs going back as far as we can get them to see what the different claims have been over time.  And those get compared with the studies that are available to see what the manufacturer should have known at any given time.

We even get whole sets of product catalogs to see what the adverstizing and product literature claimed at various times.


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