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Subject: [DCHAS-L] Query on (M)SDS and shipments
Date: Wed, 14 Aug 2013 23:42:58 -0400
Author: George D. McCallion 		Next by Date:
Subject: [DCHAS-L] Anyone using this eyewash?
Date: Thu, 15 Aug 2013 08:33:33 -0400
Author: Kim Gates

From: ILPI Support <info**At_Symbol_Here**ilpi.com>
Subject: Re: [DCHAS-L] Query on (M)SDS and shipments
Date: Thu, 15 Aug 2013 07:18:38 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: DA714B87-4292-4E00-9119-6CE44164C2B8**At_Symbol_Here**ilpi.com
In-Reply-To <8695D25C-2D13-42E0-B56E-A7FEF59C601E**At_Symbol_Here**comcast.net>


Generally no.  But depends on the normal intended end use of the material as determined by the manufacturer.  If those hazardous chemicals would be released during normal use conditions, then yes, you need an MSDS.  Otherwise, the item is an "article" and exempt from the MSDS requirement.  Emergency situations such as fires are not considered normal use.


See http://www.ilpi.com/msds/faq/partb.html#article for more examples,

See https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099 for the current version of the reg:

1910.1200(c)

Definitions. Article means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical (as determined under paragraph (d) of this section), and does not pose a physical hazard or health risk to employees. 

Best wishes,

Rob Toreki

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On Aug 14, 2013, at 11:42 PM, "George D. McCallion" <medchem**At_Symbol_Here**COMCAST.NET> wrote:

Dear DCHAS members,

I would like to know if an (M)SDS is required on all shipments of electrical devices? The device itself contains various chemical constituents. The constituents can be placed on the (M)SDS, but we need to provide and (M)SDS with every shipment?

I was looking at the OSHA/GHS regulations & statements but was unsuccessful.

Any assistance/guidance would be greatly appreciated.

Thank you in advance.

-George D. McCallion

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