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Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
Date: Friday, January 30, 2015 1:50:28 PM
Author: Melissa Charlton-Smith <charltonsmith**At_Symbol_Here**WVWC.EDU> 		Next by Date:
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
Date: Fri, 30 Jan 2015 20:48:16 +0000
Author: "Bradley, Shelly"

From: ILPI Support <info**At_Symbol_Here**ilpi.com>
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
Date: Fri, 30 Jan 2015 14:00:24 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 774819E6-85F0-4CDB-860F-03C8566F3B07**At_Symbol_Here**ilpi.com
In-Reply-To


Short answer: If you have an MSDS, just stick with it.  I would discourage anyone from making their own SDS because they would then be the "responsible party" and presumably inherit all of the legal responsibilities that brings https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=28796   And even so, use it up or dispose of it as waste to make your compliance that much easier.

Broadening the scope of that question a little more, if you don't have an MSDS of any sort, then that's a problem.  MSDS's have been required since 1986, so failure to have an (M)SDS is the employer's fault, as the manufacturer would have been able to provide one at the time the material was procured.  In my mind that is more than a de minimus violation because it means that the employer has clearly been lacking the required sheet for a significant period of time. 

Rob Toreki

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On Jan 30, 2015, at 1:22 PM, "Bradley, Shelly" <Bradley**At_Symbol_Here**HENDRIX.EDU> wrote:

Thanks!
What about when the vendor/manufacturer no longer exists?

FYI - We are a private college in a non-plan state so are regulated by federal OSHA.

Shelly Bradley
NRCC-CHO
Authorized OSHA Trainer
Instrumentation Specialist
Laboratory Development Assistant
Campus Chemical Compliance Director
Department of Chemistry
Hendrix College
Conway, AR 72032
Ph: (501) 450-3812
Fax: (501) 450-3829
bradley**At_Symbol_Here**hendrix.edu


-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Zydnia Madera
Sent: Friday, January 30, 2015 11:14 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?

See below.

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Bradley, Shelly
Sent: Friday, January 30, 2015 10:30 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] Are SDS for existing chemicals required?

Do I need GHS compliant Safety Data Sheets for existing chemicals?                 Yes, by June 1,2015
Do I still keep the original MSDS as well?                                                                         Yes, depending the states the law says for 30yrs plus the time of the employment of your employees
Do they have to be from the original manufacturer?                                                 They should be from your vendor/manufacturer.
What if the manufacturer  no longer exist?

Thanks in advance for your help,
Shelly

Shelly Bradley
NRCC-CHO
Authorized OSHA Trainer
Instrumentation Specialist
Laboratory Development Assistant
Campus Chemical Compliance Director
Department of Chemistry
Hendrix College
Conway, AR 72032
Ph: (501) 450-3812
Fax: (501) 450-3829
bradley**At_Symbol_Here**hendrix.edu


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