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: ILPITo: 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.htmlBut 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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