From: Monona Rossol <actsnyc**At_Symbol_Here**>
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
Date: Tue, 3 Feb 2015 17:08:58 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 14b517d4313-5eb8-14ce**At_Symbol_Here**

Several manufacturer's asked OSHA for a ruling about what they need to do when their raw chemical suppliers don't provide the information they need in order to develop their SDSs.  OSHA ruled that they would be exempt from the deadline as long as they could show proof of serious attempts to get that information.
So I would assume it would be the same for you.  However, simply looking in the shipment and not seeing one doesn't sound sufficient to me.  Copies of letters or e-mails documenting your failed attempt to get an updated one probably would be enough to get you off the hook.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062

-----Original Message-----
Sent: Tue, Feb 3, 2015 2:26 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 =B9t 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: <Bradley>, Shelly <Bradley**At_Symbol_Here**HENDRIX.EDU>
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Date: Friday, January 30, 2015 at 10:30 AM
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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