You are correct in noted some ambiguity in the regulations. As a former researcher on the receiving end of a manufacturer’s SDS, we would like to get that information upon ordering the material in case there would be special precautions needed for handling. Many suppliers do mail paper copies with or later than the chemical shipment, which presents a problem for scientists who may be eager to use the material and EHS professionals wanting correct safety protocols in place. Alternatively, the availability on the website may meet the minimum OSHA expectation of the word “provided” in 1910.1200(g)(6)(i), but shipping companies may want a paper copy on hand as per their procedures.
Again, speaking as a chemist, the link to the actual SDS prior to the hazardous material shipment would be considered a best practice. In the role of Hazard Communications, we try to always provide an electronic link or pdf of the appropriate SDS before and/or during shipment.
Assoc. Director, Global Hazard Communication
Teva Pharmaceuticals, Inc.
Tel: 267-468-4064 Cell: 215-272-9059
I have read the OSHA requirements for supplying SDS information to institutions who order chemicals. It is a bit vague in exactly how and when the SDS is to be provided.
From your perspective, is a paper copy of the SDS required with each shipment? If the SDS is posted on the providers website, is that sufficient to satisfy availability? Is both required?
Thank you for your input.
Product Marketing Manager – Chromatography
4700 Superior Street
Lincoln, NE 68504
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