Peter Zavon, CIH
So - let's see if I have this right:
Keep the MSDS until the manufacturer sends you an updated SDS (if they ever do), or until you fell like going out to the web and looking for one.
As we’ve been hearing from Australia and elsewhere of their criterion that an (M)SDS should be no more than 5 years old, I should mention that the US regulatory regime has NO age criterion for an (M)SDS. As long as it correctly displays the manufacturer’s correct understanding of the items in an (M)SDS, it is good, regardless of age – from a regulatory standpoint.
Thanks Kim for the extremely helpful clarification. It will be such a relief to take the college from a state of extreme noncompliance to one of compliance with OSHA regs.
From: DCHAS-L Discussion List [dchas-l**At_Symbol_Here**MED.CORNELL.EDU] on behalf of Kim Gates [kim.gates**At_Symbol_Here**STONYBROOK.EDU]
Sent: Tuesday, May 28, 2013 6:13 PM
Subject: Re: [DCHAS-L] (M)SDS access
The user is responsible for keeping the most current (m) SDS available. The manufacturer is responsible for rewriting the SDS into the new format. If the manufacturer does not rewrite the SDS, the user can keep the material and the old (m)SDS is sufficient. The same goes for container labels. Users do not have to relabel all bottles with old style labels to be in the new format.
Bottom line - don't dispose of old bottles just because you don't have a new format SDS or label. Your training will cover the new/old formats.
You are required to have an (m) SDS that matches the product name, product number and manufacturer. A sigma SDS for acetone will not meet the regulatory requirement for an SDS for a bottle of baker acetone. From a safety standpoint, sds for pure lab chemicals will be the same across manufacturers, but mixtures of non lab type chemicals will be very different.
On May 28, 2013, at 7:01 PM, "Strode, Kyle" <strode**At_Symbol_Here**carroll.edu> wrote:
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?
Forgot to add this MSDS FAQ entry in my earlier reply. It goes right to this issue: http://www.ilpi.com/msds/faq/partd.html#multimanufacturer
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On May 24, 2013, at 10:13 AM, "Strode, Kyle" <strode**At_Symbol_Here**CARROLL.EDU> wrote:
Thanks to all who have responded thus far. The information is really helpful to a new CHO.
My primary position is college chemistry professor; I am doing the CHO work as an add-on to my teaching duties. In this dual role, I am looking at chemical safety and the (M)SDS requirement as an experienced chemist and as an inexperienced safety officer.
A week ago, I finished an exhaustive look at our chemical inventory and when I matched it to our (M)SDS list, there were lots of holes, mostly from older bottles of compounds. The bottles, labels and contents were still in great shape, but for many, I couldn't locate a physical MSDS, and a quick search online didn't turn up MSDS documents from those manufacturers (some apparently don't exist anymore or have changed their names in corporate reshuffling). It seemed to me as a chemist that a bottle of sodium acetate trihydrate from one company would be identical to one from another, since both are (nominally) pure substances, as we refer to them in general chemistry class. This is the reason I am wondering if in the US, OSHA would accept an MSDS for a compound from a different manufacturer than the one whose bottle we possess. If not, I am facing the prospect of throwing away a rather large amount of stuff.
To summarize, I am hearing from all of you that
- online (M)SDS databases like ChemWatch are acceptable as long as everyone has access all the time, and
- we probably need the (M)SDS from the specific manufacturer whose chemical we have in our possession.
Thanks again for all of the excellent responses.
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