Date: Tue, 19 Jan 2010 07:33:49 -0500
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Kim Auletta <kauletta**At_Symbol_Here**NOTES.CC.SUNYSB.EDU>
Subject: Re: 4 more on MSDS's and DOT
In-Reply-To: <3DBE5CB4-E03B-4719-AAB1-D2F2B2F3889C**At_Symbol_Here**ilpi.com>


I believe the public comment period for written comments was closed on 
12/29/09. Everyone in this discussion must read the HazCom proposal! The 
preamble, while not riveting reading, is a must for all us safety folks 
who rely on MSDSs. You can access it at  
http://osha.gov/dsg/hazcom/index.html

I've heard that the proposed standard should be a "final" within 18 
months. It will then be 2 years for us to retrain everyone (the hazard 
classes are changing) & 3 years for manufacturers to rewrite & distribute 
all their new MSDSs.

Kim Auletta
Lab Safety Specialist
EH&S    Z=6200
Stony Brook University
kauletta**At_Symbol_Here**notes.cc.sunysb.edu
631-632-3032
EH&S Web site: http://www.stonybrook.edu/ehs/lab/

Remember to wash your hands!


From:
ILPI 
To:
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Date:
01/16/2010 02:20 PM
Subject:
Re: [DCHAS-L] 4 more on MSDS's and DOT
Sent by:
DCHAS-L Discussion List 


On Jan 16, 2010, at 7:47 AM, david.iacovone**At_Symbol_Here**ATT.NET wrote:

One thing I would like to see, and many of my colleagues agree, is more 
uniformity with regards to the layout of MSDSs.  There are content 
requirements, but to my knowledge, no requirement for format. 

Under the HazCom Standard, 29 CFR 1910.1200, there is no required format. 
The required *content* is found in paragraph (g); see 
http://www.ilpi.com/msds/osha/1910_1200.html#1910.1200(g)

OSHA used to recommend their own Form 174, but has encouraged the ANSI 
format for many years now.  Most manufacturers have moved towards ANSI in 
recent years, but, again, there is no regulatory mandate for that.  See:

OSHA 174 format: http://www.ilpi.com/msds/ref/osha.html
ANSI format: http://www.ilpi.com/msds/ref/ansi.html

But there is light on the horizon!

Once the US adopts the Globally Harmonized System, MSDS's will finally 
have a set format which basically mirrors the ANSI format.  It will be a 
number of years before the rule making process results in the biggest 
change to the HazCom Standard since it was written, and I think that a 
lots of folks on the list would want to contribute their thoughts during 
the public comment periods this will entail.  See:

http://www.ilpi.com/msds/ref/ghs.html and references therein.

While the "Globally Harmonized System" name suggests that MSDS's around 
the world will have the same format, there will still be some differences. 
 The GHS is a model framework only and can't be applied everywhere 
unchanged.  For example, the GHS calls for complete toxicological and 
ecological information, including consumer protection, an area that is 
outside OSHA's authority.  Likewise, GHS requires transportation 
information that, in the US, falls under DOT.  Nonetheless, it will 
greatly align MSDS's around the world and make life easier with respect to 
import/export.

Rob Toreki

  =====================================================
Safety Emporium - Lab & Safety Supplies featuring brand names
you know and trust.  Visit us at http://www.SafetyEmporium.com
esales**At_Symbol_Here**safetyemporium.com  or toll-free: (866) 326-5412
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012


I believe the public comment period for written comments was closed on 12/29/09. Everyone in this discussion must read the HazCom proposal! The preamble, while not riveting reading, is a must for all us safety folks who rely on MSDSs. You can access it at  http://osha.gov/dsg/hazcom/index.html

I've heard that the proposed standard should be a "final" within 18 months. It will then be 2 years for us to retrain everyone (the hazard classes are changing) & 3 years for manufacturers to rewrite & distribute all their new MSDSs.

Kim Auletta
Lab Safety Specialist
EH&S    Z=6200
Stony Brook University
kauletta**At_Symbol_Here**notes.cc.sunysb.edu
631-632-3032
EH&S Web site:
http://www.stonybrook.edu/ehs/lab/

Remember to wash your hands!


From: ILPI <info**At_Symbol_Here**ILPI.COM>
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Date: 01/16/2010 02:20 PM
Subject: Re: [DCHAS-L] 4 more on MSDS's and DOT
Sent by: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>



On Jan 16, 2010, at 7:47 AM, david.iacovone**At_Symbol_Here**ATT.NET wrote:

One thing I would like to see, and many of my colleagues agree, is more uniformity with regards to the layout of MSDSs.  There are content requirements, but to my knowledge, no requirement for format.

Under the HazCom Standard, 29 CFR 1910.1200, there is no required format.  The required *content* is found in paragraph (g); see http://www.ilpi.com/msds/osha/1910_1200.html#1910.1200(g)

OSHA used to recommend their own Form 174, but has encouraged the ANSI format for many years now.  Most manufacturers have moved towards ANSI in recent years, but, again, there is no regulatory mandate for that.  See:

OSHA 174 format: http://www.ilpi.com/msds/ref/osha.html
ANSI format: http://www.ilpi.com/msds/ref/ansi.html

But there is light on the horizon!

Once the US adopts the Globally Harmonized System, MSDS's will finally have a set format which basically mirrors the ANSI format.  It will be a number of years before the rule making process results in the biggest change to the HazCom Standard since it was written, and I think that a lots of folks on the list would want to contribute their thoughts during the public comment periods this will entail.  See:

http://www.ilpi.com/msds/ref/ghs.html and references therein.

While the "Globally Harmonized System" name suggests that MSDS's around the world will have the same format, there will still be some differences.  The GHS is a model framework only and can't be applied everywhere unchanged.  For example, the GHS calls for complete toxicological and ecological information, including consumer protection, an area that is outside OSHA's authority.  Likewise, GHS requires transportation information that, in the US, falls under DOT.  Nonetheless, it will greatly align MSDS's around the world and make life easier with respect to import/export.

Rob Toreki

  ======================================================
Safety Emporium - Lab & Safety Supplies featuring brand names
you know and trust.  Visit us at http://www.SafetyEmporium.com
esales**At_Symbol_Here**safetyemporium.com  or toll-free: (866) 326-5412
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012


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