If you are into overkill, for each chemical synonym listed on the SDS, make a new page with that name as the title and write a note on it such as "see the SDS for acetone". Another popular method in chemical laboratories is to file SDS' by molecular or chemical formula. The standard convention is to list carbon and hydrogen first, followed by the other chemical elements in alphabetical order.
If there is no carbon in the compound, then simple alphabetical order is used. The drawbacks here are that not all materials have chemical formulas such as cleaning agents , and this system is more difficult for non-chemists. Every case is different and we really don't feel comfortable from a legal and moral standpoint trying to address such a complex issue. Hopefully, the points raised in this document will give you an idea of the parameters involved. Take a look at the previous question for some specific insights.
The one recommendation we will make is that you maintain your paper copies. Beyond that, we'll also say that some organizations will find it very advantageous to utilize one of the " paperless compliance " services discussed in this document. But that's where our specific recommendations end, sorry.
This makes sense when you consider the following:. That said, you can use our SDS page and search engines or various Internet collections as a source to find the electronic and hard copies of SDS's that you need for your collection or to see if more recent sheets are available. While SDS's are a necessary part of these requirements, merely making these available or distributing them to employees is insufficient.
An employer's training program is to be a forum for explaining to employees, not only the hazards of the chemicals in their work area, but also how to use the information generated in the hazard communication program. This can be accomplished in many ways audio visual, classroom instruction, interactive video , and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them.
Moreover, with the advent of the HCS adoption of the GHS system , you will need to train your employees on labeling, pictograms , and other key elements of the HCS.
Yes and no. Paragraph g 2 of 29 CFR The same is true of label requirements. At first glance, it appears you do not need to make special provisions. SDS's are part of the hazard communication process and training requirements; if your employees do not understand English and you do not provide training in a language they comprehend then you are not in compliance.
This statement includes the following:. In practical terms, this means that an employer must instruct its employees using both a language and vocabulary that the employees can understand. For example, if an employee does not speak or comprehend English, instruction must be provided in a language the employee can understand.
Similarly, if the employee's vocabulary is limited, the training must account for that limitation. By the same token, if employees are not literate, telling them to read training materials will not satisfy the employer's training obligation.
As a general matter, employers are expected to realize that if they customarily need to communicate work instructions or otherworkplace information to employees at a certain vocabulary level or in language other than English, they will also need to provide safety and health training to employees in the same manner.
Of course, employers may also provide instruction in learning the English language to non-English speaking employees. Over time this may lessen the to provide OSH Act training in other languages. We suspect that point 2 grossly underestimates the cost of hazard classification as companies that used to write SDS's themselves will either have to spend considerable time learning the process or outsource their SDS production.
Nonetheless, there will be considerable cost savings based on standardization of data and formats. On an individual basis, MSDS Solutions has a simple calculator that uses 5 pieces of data to calculate your costs. That's a tough question that only an attorney should answer, especially with the U.
Given that tobacco companies seem to escape liability for selling products that are known to be defective while others are put into bankruptcy when there is scant scientific evidence supporting the claims against them, we'd be fairly reluctant to hazard a guess. You'll need to contact an attorney who specializes in product liability for a complete answer to your question. You should also make an effort to notify the manufacturer. See the OSHA interpretation, "Requirements of the HCS and the employer's ability to rely on a manufacturer's hazard determination " for futher information.
In contrast, sending an SDS to a downstream customer in the European Union incurs a responsibility for accuracy even if the supplier has not changed the sheet they received.
The firms listed there pay a nominal fee to be listed, which helps us bring you this free SDS safety information portal. To meet our visitor's needs, we have compiled this list of pertinent reference books that are terrific resources. You can also search Amazon. If you need SDS binders, wall-mounted centers, training posters, Hazard Communication labels and more, check out our on-line store, SafetyEmporium.
Unauthorized duplication or posting on other web sites is expressly prohibited. Disclaimer : The information contained herein is believed to be true and accurate, however ILPI makes no guarantees concerning the veracity of any statement. Use of any information on this page is at the reader's own risk. ILPI strongly encourages the reader to consult the appropriate local, state and federal agencies concerning the matters discussed herein.
Can I throw away old or outdated SDS's? Where can I find an SDS for an old chemical? What if I need an SDS and the manufacturer no longer exists? I thought manufacturers were required to give me one for every chemical I purchase. When does an SDS need to be revised or replaced? What is the "ready access" requirement and what is a "barrier" to ready access? What are the penalties for non-compliance with SDS requirements? We have a large site. What requirements are there for contractors or multi-employer sites?
What's the best solution for me? How do you recommend I handle my SDS collection? Some of my employees don't speak English. Do I have to make any special provisions for these workers? How much does it cost us to maintain SDS's manually? Are we protected from liability if someone is injured because an SDS supplied to us is wrong but we had no way of knowing about the error? Where can I find SDS suppliers or software?
Where can I find SDS or safety-related books and training materials? The key points are: The identity on the label must be able to be cross-referenced to the SDS All employees must be trained that you are using one SDS as representative of all vendors so there isn't confusion during an emergency. The SDS must be complete and accurate. The manufacturer listed on the SDS is willing to act as the responsible party in the event of an emergency.
There is no legal requirement for them to assist you with another company's product. Therefore, an employer may discard the original data sheet and retain only the new data sheet if a record on the original formulation is maintained. Standard Number:. October 1, Mr. I hope I have clarified this issue for you. Please feel free to contact us again. Sincerely, John A. I'm thinking it is 30 years, but want to be sure. I am interested in the federal requirements.
View all resources on SDS. If this does not answer your question, check the analysis on SDS or click here to submit a question. Disclaimer - The information provided here is intended to help our customers familiarize themselves with health and safety issues that may affect them. Legal information is not the same as legal advice -- the application of law to an individual's specific circumstances. This site and the information available through it do not, and are not intended to constitute legal or other professional advice.
Although we go to great lengths to make sure our information is accurate and useful, we recommend you consult a lawyer if you want professional assurance that our information, and your interpretation of it, is appropriate to your particular situation. All rights reserved.
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