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

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.

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From: wdwatt**At_Symbol_Here**comcast.net

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.

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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 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 

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From: ACTSNYC**At_Symbol_Here**cs.com

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

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From: kauletta**At_Symbol_Here**notes.cc.sunysb.ed 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

kauletta**At_Symbol_Here**notes.cc.sunysb.edu

631-632-3032

FAX: 631-632-9683

EH&S Web site: http://www.stonybrook.edu/eh s/lab/

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From: ACTSNYC**At_Symbol_Here**cs.com

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.

Monona