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From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Subject: Re: [DCHAS-L] SDS requirements
Date: Fri, 23 Mar 2018 15:51:50 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 43DD23EC-9B06-4FFA-A44E-2A11446978BE**At_Symbol_Here**ilpi.com
In-Reply-To


You are generally correct.  One fly in the ointment is a multi-employer work site.  There is then a requirement to provide SDS's to the other party's employees as well even though that may not formally be an employer-employee relationship.  See http://www.ilpi.com/msds/faq/partd.html#contractors This extends to all HazCom requirements, not just SDS's.

Rob Toreki

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On Mar 23, 2018, at 2:44 PM, Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU> wrote:

A quick question, perhaps:
Am I correct that SDS's are required only by OSHA to support employer's safety programs for their employees. That is, if there is no employer-employee relationship, hazard information doesn't need to follow OSHA format requirements?

The reason I ask is that I know, for example, EPA requires MSDS's be supplied to LEPCs and emergency responders upon request. Of course, as with any EPA regulation, state and local interpretation and enforcement practices vary widely.

Thanks for any insight on this.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

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