Date: Thu, 24 Feb 2011 07:54:12 -0600
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: "Long, Don" <don.long**At_Symbol_Here**WGINT.COM>
Subject: Re: MSDS Retention
In-Reply-To:

Aha - now it makes sense. I forge t about those guys sometimes.
 
Sorry.


From: DCHAS-L Discussion List [mail to:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Mary Ellen Abel
Sent: Thursday, February 24, 2011 6:37 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] MSDS Retention


Actually we are not an OSHA regulated facility, we are an MSHA regulated facility, Mine Safety Health Administrat ion.  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&q uot; <don.long**At_Symbol_Here**WGINT.COM>
Sent by: DCHAS-L Discussion List <D CHAS-L**At_Symbol_Here**list.uvm.edu>

02/23/2011 06:21 PM
Please respond t o
DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**list.uvm.edu>

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 s ure 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 bus iness 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 e mployment plus 30 years". It stands to reason that the MSDSs would fol low the same reasoning.
 
I know when the Feds audit us (Army, CDC, O SHA, etc) their response is that if it's been used then we better have an M SDS. In the Haz-Com exerpt below, it seems to make it clear that we "s hall maintain copies of any MSDSs that are received with incoming shipments...".
 

1910.1200(b)(4)(ii)

"Employers shall mai ntain copies of any material safety data sheets that are received with inco ming shipments of the sealed containers of hazardous chemicals, shall obtai n a material safety data sheet as soon as possible for sealed containers of hazardous chemicals received without a material s afety data sheet if an employee requests the material safety data sheet, an d 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 [mail to: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 p otential exposure, not the data that the MSDS was received.  So that 3 0 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 produc ts 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, Pat ricia" <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 t o
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 MS DSs.  I have been saving old copies of MSDSs for which new revisions h ave been issued.   My understanding is that this would be proof that w e did have the MSDS on file if an employee claimed twenty years later that they were exposed to a chemical and said w e did not provide them with adequate information.   I planned on keepi ng 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 pa rticularly if the revisions were not significant.   They do agree howe ver, 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 p rivileged. If you have received this message in error, please permanently d elete it, along with any files that may be attached to this message, withou t reading, printing, copying, forwarding or otherwise distributing it. Please notify the sender of the error immedi ately 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, y ou should not retain, distribute, disclose or use any of this information and you should destroy the e-mail and any a ttachments or copies.


This e-mail and any attachments contain URS Corporatio n 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 attac hments or copies.

Previous post   |  Top of Page   |   Next post



The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to secretary@dchas.org.
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.