Date: Fri, 25 Feb 2011 14:35:13 +0000
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: "Peifer, Patricia" <Patricia.Peifer**At_Symbol_Here**WESTPHARMA.COM>
Subject: Re: 6 Re: [DCHAS-L] MSDS Retention
In-Reply-To: <26609319-439C-43D5-87CF-3060DC95BDAF**At_Symbol_Here**DCHAS.ORG>

I wanted to thank every one for the great responses I got on the MSDS Retention issue.  The in formation I received has been very helpful to me in deciding how I want to handle this.  I am going to continue keeping my older r evisions of MSDSs and hope to get them into an electronic archive. 


I believe I have also b een able to convince other areas of our operation that the safest course wo uld be for them to do this as well.


Thank you everyone!

Pat Peifer

Health Safety and Train ing Team Leader

West Pharmaceutical Ser vices


From: DCHAS- L Discussion List [mailto:DCHAS-L**At_Symbol_Here**] On Behalf Of Secretary, ACS Division of Chemical Health and Safety Sent: Thursday, February 24, 2011 6:09 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] 6 Re: [DCHAS-L] MSDS Retention


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

Date: February 24, 2011 11:46:55 AM E ST

Subject: RE: [DCHAS-L] MSDS Retention



Good point.  Somehow the 30 year s 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 ES T

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 y ears' 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 screen ing MSDSs for products used in our underground mine long before Haz Com was ever developed. < /p>


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 E ST

Subject: Re: [DCHAS-L] MSDS Retention


>I agree – I see a lot of &# 8220;kits” in biology and frankly the MSDS is useless!

>It is practically impossible to k now what is in these products and how to dispose of the waste.

>I am keeping the MSDS though!!


Good.  You've done due dilliganc e and it is the manufacturer that becomes the Defendant if something goes w rong.   Monona





From: kauletta**At_Symbol_Here** u

Date: February 24, 2011 2:52:25 PM ES T

Subject: Re: [DCHAS-L] MSDS Retention



All of your suggestions as to WHY ret ention of MSDSs are valid and useful (may be needed to justify health claim s; regulatory requirement, etc). BUT - as the MSDS point person for our large university who is responsible for 19,000++ 3;+ MSDSs, I can tell you that it is a difficult and daunting task. Whe re do I store them? My "archive space" was just demolished to mak e 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 abou t in 10 years when that technology is no longer valid (I have a few zip dis cs 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.& nbsp;


Kim Auletta

Lab Safety Specialist

EH&S    Z=6200

Stony Brook University



FAX: 631-632-9683

EH&S Web site: s/lab/




From: ACTSNYC**At_Symbol_Here**

Date: February 24, 2011 12:53:40 PM E ST

Subject: Re: [DCHAS-L] MSDS Retention



Good point Edward.  When we do l itigation, 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 cat alogs to see what the adverstizing and product literature claimed at variou s times.






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