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Subject: Re: MSDS Retention
Date: Wed, 23 Feb 2011 22:09:39 -0500
Author: DrHenry
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Subject: Re: MSDS Retention
Date: Thu, 24 Feb 2011 07:54:12 -0600
Author: "Long, Don"
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Date: Thu, 24 Feb 2011 07:37:29 -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: Mary Ellen Abel <mabel**At_Symbol_Here**MORTONSALT.COM>
Subject: Re: MSDS Retention
In-Reply-To: <C3E98B533BBA314490DC0D1C18E023170EFC6D09**At_Symbol_Here**pb01msx.wgipb.local>
Actually we are not an OSHA regulated facility, we are an MSHA regulated
facility, Mine Safety Health Administration. Similar rules, not
identical, but a much different focus.
Mary Ellen Abel
Quality Assurance & Environmental Manager
Morton Salt
P.O. Box 428
Grand River, OH 44045-0428
phone: 440-639-4279
fax: 440-639-4269
cell: 440-479-9022
"Long, Don"
Sent by: DCHAS-L Discussion List
02/23/2011 06:21 PM
Please respond to
DCHAS-L Discussion List
To
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
cc
Subject
Re: [DCHAS-L] MSDS Retention
Ohio falls under the Federal OSHA, so I'm sure that facility is an "OSHA
regulated" facility.
As far as maintaining MSDSs, it's not that difficult to maintain them
electronically. We are supposed to be in the business of taking care of
folks. I don't understand the conflict here. We are already required to
maintain medical records of employees employed more than 1 year for "the
duration of employment plus 30 years". It stands to reason that the MSDSs
would follow the same reasoning.
I know when the Feds audit us (Army, CDC, OSHA, etc) their response is
that if it's been used then we better have an MSDS. In the Haz-Com exerpt
below, it seems to make it clear that we "shall maintain copies of any
MSDSs that are received with incoming shipments...".
1910.1200(b)(4)(ii)
"Employers shall maintain copies of any material safety data sheets that
are received with incoming shipments of the sealed containers of hazardous
chemicals, shall obtain a material safety data sheet as soon as possible
for sealed containers of hazardous chemicals received without a material
safety data sheet if an employee requests the material safety data sheet,
and shall ensure that the material safety data sheets are readily
accessible during each work shift to employees when they are in their work
area(s);"
Just some thoughts....
Don A. Long
CAIH, CEAS I
Southwest Research Institute Laboratory
Pine Bluff Chemical Agent Disposal Facility
PO Box 20130
White Hall, AR 71612
870-541-4930
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of
Mary Ellen Abel
Sent: Wednesday, February 23, 2011 10:05 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] MSDS Retention
It is my understanding that the '30 years' refers to the date of the last
potential exposure, not the data that the MSDS was received. So that 30
years might actually be 45 years, if that individual used it for a period
beyond its first use. Although I am not in an OSHA regulated facility, we
have been screening MSDSs for products used in our underground mine long
before Haz Com was ever developed.
Mary Ellen Abel
Quality Assurance & Environmental Manager
Morton Salt
P.O. Box 428
Grand River, OH 44045-0428
phone: 440-639-4279
fax: 440-639-4269
cell: 440-479-9022
"Peifer, Patricia"
Sent by: DCHAS-L Discussion List
02/23/2011 09:17 AM
Please respond to
DCHAS-L Discussion List
To
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
cc
Subject
[DCHAS-L] MSDS Retention
A debate has come up within our organization concerning the retention of
MSDSs. I have been saving old copies of MSDSs for which new revisions
have been issued. My understanding is that this would be proof that we
did have the MSDS on file if an employee claimed twenty years later that
they were exposed to a chemical and said we did not provide them with
adequate information. I planned on keeping them for thirty years.
Others in my organization feel I may be wasting my time. They feel I
should be throwing out older versions and only retaining the latest copy
particularly if the revisions were not significant. They do agree
however, that I should be keeping old MSDSs for chemicals for which we
discontinue use.
Any thoughts? Thank you, everyone.
Pat Peifer
Health Safety and Training Team Leader
West Pharmaceutical Services
Find West on Twitter and LinkedIn.
The contents of this message are confidential and may be privileged. If
you have received this message in error, please permanently delete it,
along with any files that may be attached to this message, without
reading, printing, copying, forwarding or otherwise distributing it.
Please notify the sender of the error immediately so that we can prevent
it from happening again.
This e-mail and any attachments contain URS Corporation confidential
information that may be proprietary or privileged. If you receive this
message in error or are not the intended recipient, you should not retain,
distribute, disclose or use any of this information and you should destroy
the e-mail and any attachments or copies.
Actually we are not an OSHA regulated
facility, we are an MSHA regulated facility, Mine Safety Health Administration.
Similar rules, not identical, but a much different focus.
Mary Ellen Abel
Quality Assurance & Environmental Manager
Morton Salt
P.O. Box 428
Grand River, OH 44045-0428
phone: 440-639-4279
fax: 440-639-4269
cell: 440-479-9022
"Long, Don" <don.long**At_Symbol_Here**WGINT.COM>
Sent by: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**list.uvm.edu>
02/23/2011 06:21 PM
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Please respond to
DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**list.uvm.edu> |
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To
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|
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cc
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Subject
| Re: [DCHAS-L] MSDS Retention |
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Ohio falls under the Federal OSHA, so I'm
sure that facility is an "OSHA regulated" facility.
As far as maintaining MSDSs, it's not that
difficult to maintain them electronically. We are supposed to be in the
business of taking care of folks. I don't understand the conflict here.
We are already required to maintain medical records of employees employed
more than 1 year for "the duration of employment plus 30 years".
It stands to reason that the MSDSs would follow the same reasoning.
I know when the Feds audit us (Army, CDC,
OSHA, etc) their response is that if it's been used then we better have
an MSDS. In the Haz-Com exerpt below, it seems to make it clear that we
"shall maintain copies of any MSDSs that are received with incoming
shipments...".
1910.1200(b)(4)(ii)
"Employers shall maintain
copies of any material safety data sheets that are received with incoming
shipments of the sealed containers of hazardous chemicals, shall obtain
a material safety data sheet as soon as possible for sealed containers
of hazardous chemicals received without a material safety data sheet if
an employee requests the material safety data sheet, and shall ensure that
the material safety data sheets are readily accessible during each work
shift to employees when they are in their work area(s);"
Just some thoughts....
Don A. Long
CAIH, CEAS I
Southwest Research Institute Laboratory
Pine Bluff Chemical Agent Disposal Facility
PO Box 20130
White Hall, AR 71612
870-541-4930
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu]
On Behalf Of Mary Ellen Abel
Sent: Wednesday, February 23, 2011 10:05 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] MSDS Retention
It is my understanding that the '30 years' refers to the date of the last
potential exposure, not the data that the MSDS was received. So that
30 years might actually be 45 years, if that individual used it for a period
beyond its first use. Although I am not in an OSHA regulated facility,
we have been screening MSDSs for products used in our underground mine
long before Haz Com was ever developed.
Mary Ellen Abel
Quality Assurance & Environmental Manager
Morton Salt
P.O. Box 428
Grand River, OH 44045-0428
phone: 440-639-4279
fax: 440-639-4269
cell: 440-479-9022
"Peifer, Patricia"
<Patricia.Peifer**At_Symbol_Here**WESTPHARMA.COM>
Sent by: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**list.uvm.edu>
02/23/2011 09:17 AM
|
Please respond to
DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**list.uvm.edu> |
|
|
To
| DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
|
|
cc
|
|
|
Subject
| [DCHAS-L] MSDS Retention |
|
A debate has come up within our organization concerning the retention of
MSDSs. I have been saving old copies of MSDSs for which new revisions
have been issued. My understanding is that this would be proof that
we did have the MSDS on file if an employee claimed twenty years later
that they were exposed to a chemical and said we did not provide them with
adequate information. I planned on keeping them for thirty years.
Others in my organization feel I may be wasting my time. They feel
I should be throwing out older versions and only retaining the latest copy
particularly if the revisions were not significant. They do agree
however, that I should be keeping old MSDSs for chemicals for which we
discontinue use.
Any thoughts? Thank you, everyone.
Pat Peifer
Health Safety and Training Team Leader
West Pharmaceutical Services
Find West on Twitter
and LinkedIn.
The contents of this message are confidential and may
be privileged. If you have received this message in error, please permanently
delete it, along with any files that may be attached to this message, without
reading, printing, copying, forwarding or otherwise distributing it. Please
notify the sender of the error immediately so that we can prevent it from
happening again.
This e-mail and any attachments contain URS
Corporation confidential information that may be proprietary or privileged.
If you receive this message in error or are not the intended recipient,
you should not retain, distribute, disclose or use any of this information
and you should destroy the e-mail and any attachments or copies.
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