From: ILPI Support <info**At_Symbol_Here**ilpi.com>
Subject: Re: [DCHAS-L] Customer Expectations/Requirements for SDS at time of Purchase
Date: Tue, 13 Sep 2016 16:53:51 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 32ADAA11-E92F-4172-8CCB-7703C9A2198B**At_Symbol_Here**ilpi.com
In-Reply-To


Just to be clear on this point, a manufacturer ***DOES NOT*** meet their regulatory requirements for providing/transmitting an SDS merely by having it available on their web site, and referring customers to their web site does not meet the transmission requirements of the HazCom Standard.


Manufacturers can optionally fulfill their obligation this way with ***specific customers*** as long as they have a prior agreement per the detailed procedure at http://www.ilpi.com/msds/osha/cpl0202079.html#G.1.p which I mentioned in my prior post.

See this OSHA interpretation letter dated May 13, 2013 titled "Electronic distribution of safety data sheets (SDSs) under the revised Hazard Communication standard" at http://www.ilpi.com/msds/osha/I20130513.html for further confirmation.

Rob Toreki

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On Sep 13, 2016, at 4:06 PM, Kurt Josef <Kurt.Josef**At_Symbol_Here**TEVAPHARM.COM> wrote:

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.
 
 
Kurt Josef
Assoc. Director, Global Hazard Communication
Teva Pharmaceuticals, Inc.
Tel: 267-468-4064     Cell: 215-272-9059
 
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Lewis, Ronald L
Sent: Tuesday, September 13, 2016 12:14 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] Customer Expectations/Requirements for SDS at time of Purchase
 
To All,
 
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.
 
=46rom 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.
 
Ron Lewis
Teledyne ISCO
Product Marketing Manager - Chromatography
4700 Superior Street
Lincoln, NE 68504
Direct 402-465-2076
Mobile 402-304-1511
 
 
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