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Subject: Re: [DCHAS-L] Legacy chemicals and old MSDSs

Date: Jun 6, 2025 15:44 UTC

Author: Stephen Taylor <stephen**At_Symbol_Here**LABSAFETYINSTITUTE.ORG>

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Subject: Re: [DCHAS-L] Legacy chemicals and old MSDSs

Date: Jun 6, 2025 16:37 UTC

Author: Alex Hagen <fischera**At_Symbol_Here**UW.EDU>

From: Info <info**At_Symbol_Here**ILPI.COM>

Subject: Re: [DCHAS-L] Legacy chemicals and old MSDSs

Date: Jun 6, 2025 16:25 UTC

Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>

Message-ID: <B0E91679-954B-4B71-BDE0-C35B656DABE5**At_Symbol_Here**ilpi.com>

In-Reply-To: <1407113818.301609.1749173898460**At_Symbol_Here**mail.yahoo.com>

Demystify: 
You can make an SDS for anything you want as long as you are willing to be the “responsible party" listed on the sheet. That, of course, carries all the liabilities associated therewith.

See http://www.ilpi.com/msds/faq/partc.html#contact (As a distributor, can we change the name and address on an SDS?) for additional insight. And note that the SDS and label must match once you do that. 

Also see http://www.ilpi.com/msds/faq/partc.html#whocan (Who can write an SDS?)

Having repackaged the material (with that new label even if you didn’t change the container) you now meet the OSHA definition of “chemical manufacturer” which is:

"an employer with a workplace where chemical(s) are produced for use or distribution". Generally, this means any employer that manufactures, processes, formulates, or repackages a hazardous chemical. See http://ilpi.com/msds/ref/manufacturer.html 

As far as solving your issue, a witty person might point out that this exercise is like using an Excel spreadsheet that sets cell A to cell B and cell B to cell A…it’s circular reasoning because, as the manufacturer, you’d need to have an SDS for the ingredients you use from their manufacturers, and you’re back to square one. However, arguably you don’t get the ingredients anywhere since there is nobody that supplies it and I doubt an OSHA inspector would bother or care, particularly as the Standard is performance-based and you documented your good faith efforts to resolve the issue.  IMO, it wouldn’t even merit a de minimus violation.

Also see http://www.ilpi.com/msds/osha/I19951127A.html for an old Interpretation about repackaging.

Stay safe!

Rob Toreki

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On Jun 5, 2025, at 9:38 PM, Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote:

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



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