From:
James Keating <james.k.keating**At_Symbol_Here**GMAIL.COM>
Subject:
Re: [DCHAS-L] Legacy chemicals and old MSDSs
Date:
Jun 6, 2025 15:02 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
<CAM1PioPGCfkMB=eTuZEtB4=fgp2EvFE_XfBta-AZvgovO-39pw**At_Symbol_Here**mail.gmail.com>
In-Reply-To:
<1407113818.301609.1749173898460**At_Symbol_Here**mail.yahoo.com>
Monona,
If you want to keep some of the legacy chemicals find the successor manufacturer or distributor and compare the chemical abstract percentages with the original and use the SDS for the replacement chemical. If this solution is unavailable then review the MSDS and make sure all 16 sections are listed and continue to use the legacy MSDS, otherwise hire an environmental company to dispose of the legacy chemicals.
The use of the legacy MSDS should no more than a deminimis violation.
Jim Keating
That would be great. You don't even have to do it anonymously, just say I'm shy.
And a 4th question: If we wanted to keep a legacy chemical for which the manufacturer is out of business, can we write an SDSs as the "manufacturer of record" and take responsibility for the material?
I'm thinking of a school that found 30 year old 50# bags of a mineral called Albany Slip. The mines for the slip ran out in the 1980s. This glaze mineral is very desirable and worth a lot of money. But like all minerals, it has some hazards. There are many analyses of this mineral to work up an SDS from.
And there are other substances that people might want to keep.
I'm really interested in this subject. Monona
Hi Monona.
Would you like me to ask OSHA anonymously for you. ... Jim
James A. Kaufman, Ph.D.
Founder, LSI
Serving Industry, Government, & Academia for 50 years
508-574-6264
I remember we had a long conversation some years ago about legacy chemicals,so hopefully there are still people on this forum who can give me some guidance on the following questions.
1. Can OSHA cite an employer who has old MSDSs in their hazcom or lab standard files for workers reference?
2. And can they cite if the old MSDSs are for legacy products if the manufacturer no longer makes the product or is out of business?
3. What are the legal issues associated with using products in the workplace for which the manufacturer no longer claims liability?
I'm desperate for some kind of legal or OSHA guidance on this for some theater shops where we have workers.
Monona
M. Rossol, President
Arts, Crafts & Theater Safety
181 Thompson St., #23New York NY 10012
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