Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
Date: Tue, 3 Feb 2015 21:10:31 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: D7EA725DFFBD7C4AB0A9875D988A5E3B3F6E6C3A**At_Symbol_Here**
In-Reply-To <61BC62219B0F36459A04DD8D3BA5DE210153E264C7**At_Symbol_Here**>

HazCom has specific requirements for labs that echo the lab standard.

This section applies to laboratories only as follows:

Employers shall ensure that labels on incoming containers of hazardous
chemicals are not removed or defaced;

Employers shall maintain any safety data sheets that are received with
incoming shipments of hazardous chemicals, and ensure that they are
readily accessible during each workshift to laboratory employees when they
are in their work areas;

Employers shall ensure that laboratory employees are provided information
and training in accordance with paragraph (h) of this section, except for
the location and availability of the written hazard communication program
under paragraph (h)(2)(iii) of this section; and,

Laboratory employers that ship hazardous chemicals are considered to be
either a chemical manufacturer or a distributor under this rule, and thus
must ensure that any containers of hazardous chemicals leaving the
laboratory are labeled in accordance with paragraph (f) of this section,
and that a safety data sheet is provided to distributors and other
employers in accordance with paragraphs (g)(6) and (g)(7) of this section."

I suggest that you donÁøt make yourself crazy looking for manufacturer
specific SDSs of Á¡oldÁ± chemicals. If you have an SDS from a reputable
source for the chemical that should satisfy a CSHO.

-----Original Message-----
From: , Brad
Reply-To: DCHAS-L
Date: Tuesday, February 3, 2015 at 2:40 PM
To: "DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU"
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?

>The Lab Standard generally defers to the HazCom Standard on the issue of
>Safety Data Sheets and labels, except for certain situations. The
>following is general guidance from OSHA on safety data sheets. This has
>not changed with GHS adoption. The following is paraphrased from -
> and this recent guidance:
> :
>OSHA says: Employers are required to have SDSs for all hazardous
>chemicals that they use
>If you do not receive an SDS automatically, you must request one as soon
>as possible. If you cannot show a good faith effort to receive the SDS,
>you can be cited for not having the SDS for a hazardous chemical
>If any are missing, contact your supplier and request one. It is a good
>idea to document these requests, either by keeping a copy of a letter or
>e-mail, or a note regarding telephone conversations
>Do not allow workers to use any hazardous chemicals for which you have
>not received an SDS. The SDS provides information you need to ensure that
>proper protective measures are implemented prior to worker exposure.
>If you receive an SDS that is obviously inadequate, with, for example,
>blank spaces, you must request an appropriately completed one.
>If your request for an SDS or for a corrected SDS does not produce the
>information needed, you should contact your local OSHA area office for
>assistance in obtaining the SDS.
>Some suppliers provide SDSs for products that are not hazardous. These
>SDSs do not have to be maintained.
>OSHA Says: In order to ensure that you have a current SDS for each
>chemical in the plant as required, and that worker access is provided,
>OSHA's CSHOs will be looking for the following items in your program:
>Designation of person(s) responsible for obtaining and maintaining the
>How such sheets are maintained in the workplace (e.g., in notebooks in
>the work area(s) or electronically), and how workers obtain access to
>them when they are in their work area during the work shift;
>Procedures to follow when the SDS is not received at the time of the
>first shipment;
>An SDS for each hazardous chemical in the workplace, and training of
>workers that includes review of SDS format and use.
>Brad Harbaugh
>Direct: 1.312.881.2855
>Visit us at:
>-----Original Message-----
>From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf
>Sent: Tuesday, February 03, 2015 1:25 PM
>Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
>The lab standard requires that: "1910.1450(h)(1)(ii) Employers shall
>maintain any safety data sheets that are received with incoming shipments
>of hazardous chemicals, and ensure that they are readily accessible to
>laboratory employees"
>So if the vendor or manufacturer did not supply an SDS it doesn©št appear
>you must have one. I am not sure OSHA can require you to produce an SDS
>if you say that it was not supplied with the chemical.
>Matt Finucane
>Executive Director
>Environmental Health and Radiation Safety University of Pennsylvania
>Phone: 215.898.6057
>Mobile: 215.651.0551
>-----Original Message-----
>From: , Shelly
>Reply-To: DCHAS-L
>Date: Friday, January 30, 2015 at 10:30 AM
>To: "DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU"
>Subject: [DCHAS-L] Are SDS for existing chemicals required?
>>Do I need GHS compliant Safety Data Sheets for existing chemicals?
>>Do I still keep the original MSDS as well?
>>Do they have to be from the original manufacturer?
>>What if the manufacturer no longer exist?
>>Thanks in advance for your help,
>>Shelly Bradley
>>Authorized OSHA Trainer
>>Instrumentation Specialist
>>Laboratory Development Assistant
>>Campus Chemical Compliance Director
>>Department of Chemistry
>>Hendrix College
>>Conway, AR 72032
>>Ph: (501) 450-3812
>>Fax: (501) 450-3829

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