The regulation that you are required to comply with is 29CFR 1910.1450 Laboratory Standard not HAZCOM if you are a research lab. OSHA still has to come out with a CPL or Memorandum addressing how HAZCOM 2012 applies to 1910.1450.
That said, here are my thoughts:
1.- It is always good to have a (M)SDS form each supplier. I had always asked for the most current one when I was in R&D. But what is required is that you have one for each specific chemical as a minimum.
2- You can use any labelling system you want to use i.e.- HMIS/NFPA but you are being proactive by incorporating the GHS. Don't forget the training of all on your system. For multiple concentrations of reagents I would use the GHS classification and have the concentration along with the reagent name on the bottle/box. You can also have your own coding system if everyone has been trained in it and finally. The labelling requirements are relaxed a bit if and only if a container (i.e. beaker) is use by one person for that shift only. That container just cannot be left out in the open by itself.
3. Yes there are several software packages out there that will allow you to inventory/ track volumes link to a website to get MSDS and some even will print a bar code that can be attached to the storage container.
Hope this helps!
Michael A. Buczynski
Director Regulatory Compliance
RB (Reckitt Benckiser)
399 Interpace Parkway
Parsippany, NJ USA 07054-0225
Please think before you print.
My answers are:
1. Yes, it would be good to have an SDS from each vendor as one might use a different inhibitor/stabilizer than others do. Also it would probably be good to archive your older MSDSs simply because of potential liability issues.
2. It would be good to refer to the appendices of 29 CFR 1910.1200, especially Appendix E, to be certain you have the correct GHS labels. Remember there will likely be overlapping of concentrations that will have the same GHS requirement, e.g., both 1M and 6M nitric acid are corrosive and would require the GHS Corrosion Label. Also, different information is required depending on whether the container is an original container from the supplier, a secondary container, or a portable container. Again, see especially Appendix E of 1910.1200.
3. There are commercial software packages that are available that can help with creating an inventory. However, these can be a bit pricey. Creating your own inventory would likely be less costly but could ultimately be quite time consuming. A good spreadsheet would be invaluable.
Robert Weeks, Ph.D.
I am working on our yearly chemical inventory and making labels so we will be in compliance with the GHS labeling. I have three questions I don't know the answers to:
1. If I have multiple bottles of the same chemical, from different vendors, do I need SDS's from each vendor? And some of my bottles are really old, the vendors no longer exist, but the chemical is fine, so what SDS's do I use for those?
2. If I have a solution of say NaOH, that I made up myself, but keep around for months, I know it needs to have a GHS label. However, clearly a 0.10 M NaOH solution isn't as hazardous as the solid is, and I have bottles of 5 or 6 different concentrations, from 0.10 M to 6.0 M, and they'd all have different hazards. The more dilute they are, the less dangerous, and the less requirement for PPE, so it doesn't seem like they should have the same label, or SDS sheet. If they don't need to, where do I get the solution SDS's and who's name, address and phone number belongs on the label? My name, because I made the solution, or the vendor of the solid I used to make the solution?
3. Is there an inexpensive way to make the inventory, get the right SDS's and print the GHS labels?
Thanks, feel free to email me directly, or to answer to the list serve.
Lead Chemistry Instructor
Western Technical College
400 7th St. N.
LaCrosse, WI 54601
"It's better to be careful 100 times, than to be killed once."
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