On Sep 13, 2016, at 4:06 PM, Kurt Josef <Kurt.Josef**At_Symbol_Here**TEVAPHARM.COM> wrote:

You are correct in noted some ambiguity in the regulations.  As a former researcher on the receiving end of a manufacturer's SDS, we would like to get that information upon ordering the material in case there would be special precautions needed for handling.  Many suppliers do mail paper copies with or later than the chemical shipment, which presents a problem for scientists who may be eager to use the material and EHS professionals wanting correct safety protocols in place.  Alternatively, the availability on the website may meet the minimum OSHA expectation of the word "provided" in 1910.1200(g)(6)(i), but shipping companies may want a paper copy on hand as per their procedures.

Again, speaking as a chemist, the link to the actual SDS prior to the hazardous material shipment would be considered a best practice.  In the role of Hazard Communications, we try to always provide an electronic link or pdf of the appropriate SDS before and/or during shipment.

 

 

Kurt Josef

Assoc. Director, Global Hazard Communication

Teva Pharmaceuticals, Inc.

Tel: 267-468-4064     Cell: 215-272-9059

Kurt.Josef**At_Symbol_Here**tevapharm.com    www.tevapharm.com

 

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Lewis, Ronald L
Sent: Tuesday, September 13, 2016 12:14 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] Customer Expectations/Requirements for SDS at time of Purchase

 

To All,

 

I have read the OSHA requirements for supplying SDS information to institutions who order chemicals. It is a bit vague in exactly how and when the SDS is to be provided.

 

=46rom your perspective, is a paper copy of the SDS required with each shipment? If the SDS is posted on the providers website, is that sufficient to satisfy availability? Is both required?

 

Thank you for your input.

 

Ron Lewis

Teledyne ISCO

Product Marketing Manager - Chromatography

4700 Superior Street

Lincoln, NE 68504

Direct 402-465-2076

Mobile 402-304-1511

 

www.ISCO.com/RF

 

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