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Previous by Date: Subject: Re: [DCHAS-L] (M)SDS access Date: May 24, 2013 11:11:06 AM EDT Author: "Bradley, Shelly" |
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If the power’s out, ya’ll should be out of the building anyway or at least not working with chemicals. And if your Fire folks are like my Fire folks, they
have electronic access to multiple (M)SDS resources on the rig, if it’s an emergency causing the power outage.
I encourage my folks to have paper copies of the (M)SDS for the chemicals they use all the time, every day. And paper copies of the half dozen or so most hazardous
materials they work with. Typically, it ends up being maybe 12 or 15 hardcopy (M)SDS. Then to place a link on the shared computers to the (M)SDS database.
Sez me!
Debbie M. Decker, CCHO
Safety Manager
Department of Chemistry
University of California, Davis
1 Shields Ave.
Davis, CA 95616
(530)754-7964
(530)304-6728
dmdecker**At_Symbol_Here**ucdavis.edu
Birkett's hypothesis: "Any chemical reaction
that proceeds smoothly under normal conditions,
can proceed violently in the presence of an idiot."
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU]
On Behalf Of Bradley, Shelly
Sent: Friday, May 24, 2013 8:11 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] (M)SDS access
Doesn’t the requirement for (M)SDS access even during a power outage by default require paper copies? Or am I missing something?
Shelly Bradley
NRCC-CHO
Authorized OSHA Trainer
Instrumentation Specialist
Laboratory Development Assistant
Campus Chemical Compliance Director
Department of Chemistry
bradley**At_Symbol_Here**hendrix.edu
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU]
On Behalf Of ILPI Support
Sent: Friday, May 24, 2013 6:55 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] (M)SDS access
Our MSDS FAQ has not yet been updated for GHS, but these two requirements do not appear to have changed.
http://www.ilpi.com/msds/faq/partd.html#paperless - paperless compliance
http://www.ilpi.com/msds/faq/partd.html#readyaccess the "ready access" requirement.
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
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On May 23, 2013, at 10:02 PM, Peter Zavon <pzavon**At_Symbol_Here**ROCHESTER.RR.COM> wrote:
The OSHA requirements of (M)SDS availability are not changing. You can make them available on line, as long as there are no impediments to access. For example, no individual who ought to have access should have to go to a supervisor’s office or seek help or permission from another to get on line and review one. (This is paraphrasing an OSHA representative presenting on the Hazcom 2012 implementation this week at the AIHce in Montreal.) In addition, you must have some sort of backup function to provide immediate access to (M)SDS in the event of a power failure, etc., when access is needed.
On the issue of whether it would be acceptable to make available an Aldrich (M)SDS on sodium hydroxide when your NaOH is from Fisher, my less authoritative response is that my impression of the HazCom 2012 changes would make that UNacceptable. But others may read it differently.
Peter Zavon, CIH
Penfield, NY
PZAVON**At_Symbol_Here**Rochester.rr.com
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Strode, Kyle
Sent: Thursday, May 23, 2013 2:35 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] (M)SDS access
I am in the process of deciding whether to recommend that my college pay to subscribe to an (M)SDS service (ChemWatch) or download and store my own repository of (M)SDS pdf's. I'd be grateful for your thoughts about the proper way to manage access to (M)SDS by employers.
- Do we have to have paper copies storied in a physical shelf location, or is a site license to ChemWatch OK. Can I simply maintain an easily accessible link to a folder of downloaded pdf's on our server?
- If I have a bottle of sodium hydroxide from Fisher and a downloaded (M)SDS for NaOH from Aldrich, does that meet the OSHA requirement?
- Are others using ChemWatch, and is it a good system (worth the money)?
- Are there other considerations I should be aware of as I weigh the $2000 yearly fee against the tedium of maintaining the system myself?
Thanks for your thoughts!
Kyle Strode
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