Who is required to have msds sheets

And, of course, from a legal liability standpoint meeting or exceeding OSHA standards is probably a good idea. Bottom line: If you're not sure what laws are applicable in your situation, especially if you work for a public agency, contact your local OSHA compliance office ; they might be able to direct you to appropriate agencies. The HazCom standard does not specify a minimum amount, for good reason. Some chemicals are exceedingly dangerous in even milligram quantities while others are not.

There is no way that the Standard could anticipate and determine the potentially toxic effects of over ,, known chemical compounds as of June and their mixtures. The only exception for this is when the material can release only a "very small quantities", i. That does not mean a small amount.

When trying to make a case for "trace amount", one has to consider if it is possible for an individual to be exposed to an amount of material that could cause harm. Likewise, the continuous release of just 25 ppm of hydrogen sulfide could cause serious harm! Remember, OSHA does does not define something as hazardous in a particular amount.

Per OSHA:. Risk is a function of the inherent hazard and level of exposure. A substance either is or is not a hazardous chemical; the HCS definition cannot be read to indicate that a substance could be a hazardous chemical in some concentrations but not in others.

To summarize, an SDS is required in almost every case unless there is essentially no way that the amount of material could cause harm. For additional information see this OSHA interpretation as well as this interpretation titled " Requirement to disclose all chemicals having scientific evidence that they pose a health risk regardless of concentrations present in the product on the MSDS.

If a material is hazardous and not listed below, then it generally requires an SDS:. An "article" means a manufactured item: 1 which is formed to a specific shape or design during manufacture 2 which has end use function s dependent in whole or in part upon its shape or design during end use; and 3 which does not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use. Any product which meets the definition of an "article," would be exempt from the requirements of the Standard.

For example, a roll of copper electrical wire sold to a hardware store would fit this definition of an article and would not require an SDS. However, a load of copper ingots being shipped to a computer chip manufacturer would not meet the definition of an article and would require an SDS.

The definition has been amended to permit the release of "very small quantities, e. In evaluating an article, one must consider the health risk which exposure to that article presents. The term "risk" as opposed to "hazard" is used here, since the hazard is an inherent property of the chemical and exists no matter the quantity of exposure.

To be exempted as an article, exposure must not pose a risk to employee health. Note that OSHA cannot make an across-the-board determination of a products' exclusion as an "article. Consequently, a blanket exemption for specific products cannot be given by OSHA. Food and food products are Exempt items generally include food or alcoholic beverages which are sold, used, or prepared in a retail establishment such as a grocery store, restaurant, or drinking place , and foods intended for personal consumption by employees while in the workplace.

HOWEVER : if, under normal conditions of use, [the] product could result in a hazardous exposure situation for downstream employees who will be working with or otherwise handling that product then an SDS is required. For example, flour dust poses an explosion hazard and would require an SDS. Cosmetics which are packaged for sale to consumers in a retail establishment, and cosmetics intended for personal consumption by employees while in the workplace are generally exempt.

Therefore, your supermarket doesn't need SDS's if they sell prepackaged cosmetics, but your local beauty salon which uses these occupationally or a cosmetic manufacturing plant would require SDS's. Drugs regulated by the U. However, section b 6 vii of the HCS exempts FDA drugs when in solid final form, such as tablets or pills, for direct administration to the patient. Examples of those needing SDS's for drugs would include pill manufacturing facilities and pharmacies if the drug is compounded, crushed etc.

Note: Remember that SDS's are not meant for consumers. Given the likelihood of patient confusion, most drug companies do not make their SDS's freely available to the general public. SDS's for drugs are the most difficult to find on the Internet and usually require direct contact with the manufacturer. Tip : Be certain that you properly label and account for your waste materials.

The HazCom standard does not apply to tobacco and tobacco products. Therefore, these do not generally require SDS's. We have no further information concerning the HazCom standard and tobacco. Please contact us if you can enlighten us. The standard does not apply to wood or wood products, including lumber which will not be processed, where the chemical manufacturer or importer can establish that the only hazard they pose to employees is the potential for flammability or combustibility wood or wood products which have been treated with a hazardous chemical covered by this standard, and wood which may be subsequently sawed or cut, generating dust, are not exempted.

Hardwood dusts pose a carcinogenic hazard. Likewise, wood preservatives such as chromium copper arsenate CCA also pose hazards. It is an essential starting point for the development of a complete health and safety program. It also contains information on the use, storage, handling and emergency procedures all related to the hazards of the material. The MSDS contains much more information about the material than the label.

MSDSs are prepared by the supplier or manufacturer of the material. It is intended to tell what the hazards of the product are, how to use the product safely, what to expect if the recommendations are not followed, what to do if accidents occur, how to recognize symptoms of overexposure, and what to do if such incidents occur. These categories are specified in the Controlled Products Regulations and include:.

Yes, as long as two conditions are met. All headings and subheadings that are on the MSDS must be addressed by providing the required information or by stating that the information is not available or not applicable, whichever is appropriate.

Second, the statement "This product has been classified in accordance with the hazard criteria of the CPR and the MSDS contains all of the information required by the CPR" must appear under the section heading "Regulatory Information". When employers have information about the chemicals being used, they can take steps to reduce workplace exposures, substitute less hazardous materials, and establish proper work practices.

In your letter you raised concern that you must have a MSDS for "materials that can be purchased on the grocery store shelf. Your letter mentions such items as "dishwashing soap, rubbing alcohol, Clorox bleach and other miscellaneous cleaning products. If, however, an employee's job goes beyond normal household use e. In your letter you also stated that "if somebody were poisoned in my office my first reaction would not be to run to the file cabinet and pull out one of these forms.

As a physician I would treat the problem appropriately and if necessary consult a poison control center. This information is not provided only to respond to "poisoning" incidents once they occur; it is necessary for you, the employer, to use in order to properly design and implement protective programs for your workplace.

Employers shall have a material safety data sheet in the workplace for each hazardous chemical which they use. Each material safety data sheet shall be in English although the employer may maintain copies in other languages as well , and shall contain at least the following information:.

The identity used on the label, and, except as provided for in paragraph i of this section on trade secrets:. If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common name s of the ingredients which contribute to these known hazards, and the common name s of the mixture itself; or,.

The chemical and common name s of all ingredients which have been determined to present a physical hazard when present in the mixture;. Physical and chemical characteristics of the hazardous chemical such as vapor pressure, flash point ;. The physical hazards of the hazardous chemical, including the potential for fire, explosion, and reactivity;.

The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical;. The OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the material safety data sheet, where available;.

Any generally applicable precautions for safe handling and use which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks;.

Any generally applicable control measures which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, such as appropriate engineering controls, work practices, or personal protective equipment;. The date of preparation of the material safety data sheet or the last change to it; and,. The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.

If no relevant information is found for any given category on the material safety data sheet, the chemical manufacturer, importer or employer preparing the material safety data sheet shall mark it to indicate that no applicable information was found. Where complex mixtures have similar hazards and contents i. The chemical manufacturer, importer or employer preparing the material safety data sheet shall ensure that the information recorded accurately reflects the scientific evidence used in making the hazard determination.

If the chemical manufacturer, importer or employer preparing the material safety data sheet becomes newly aware of any significant information regarding the hazards of a chemical, or ways to protect against the hazards, this new information shall be added to the material safety data sheet within three months.

If the chemical is not currently being produced or imported the chemical manufacturer or importer shall add the information to the material safety data sheet before the chemical is introduced into the workplace again.