You will NOT need to replace all your old MSDS with SDS in the new format, although that will happen over time as you acquire new materials.
The onus is on the manufacturer or importer to move to the new SDS format (if they are not there already) and to provide them, as before, with the first shipment to a new customer and when there is new or revised information (i.e. a significant change). Many suppliers also make their MSDS available on line and you could, if you wanted, mine those resources for the SDS of something you already have an MSDS for – but that is not a requirement.
If you have an MSDS for an item for which the manufacturer is out of business, for example, there will be no requirement that you get or create an SDS, nor is there a requirement that you discard the material. However, if you have a material for which you do not now have an MSDS, and you are unable to find one (for whatever reason) and don’t care for the liability of trying to create one on your own, then you are already well advised to discard.
As to generic SDS from an on-line service, I don’t see how that can cover anyone when the requirement is for an SDS from the specific supplier. I think someone has noted that sometimes there is a little informal leeway for some of the more commodity-like chemicals, but why rely on “sometimes.”?
For every excellent answer and piece of helpful information, I generate another question. Here is my next one:
I’ve just finished a comprehensive bottle-by-bottle inventory of everything we have on the shelf. I’ve culled lots of old bottles and readied them for hazardous waste disposal.
However, I have oldish bottles of chemicals that are still in good shape and are still being used. I DO have copies of the MSDS for many of these chemicals. I am planning to scan these into electronic format for our growing database. However, what happens when we switch fully to SDS?
1. Is the old scanned MSDS good enough? I’m assuming it is not and I must switch fully to SDS.
2. Assuming (as Rob points out below in the link) that I need an MSDS for the chemical from the specific manufacturer I have on the shelf, will I be able to find a new SDS for that specific bottle?
3. If the answer to #2 is no, do I need to plan to dispose of any bottles for which I can’t find an SDS?
4. Will an online SDS subscription service cover me and my institution even if they don’t provide an SDS that is specific to the manufacturer (assuming they have a general one)?
I’d be very grateful for any help with this.
I’d also be grateful for wisdom from those of you out there who are in the process of figuring out what to do with your inventory of aging chemicals in light of the switch to the SDS system. Are others among you facing the prospect of disposing of large numbers of chemicals that are still usable because you lack the MSDS or you may in the future lack the SDS?
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