Ah, yes, the carve outs of the state plan states. In those, the state and local employees may be exempt as well. http://www.ilpi.com/msds/faq/partb.html#exempt and https://www.osha.gov/dcsp/osp/index.html

Rob Toreki

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On Mar 23, 2018, at 3:06 PM, Edward Movitz <movitz**At_Symbol_Here**OLEMISS.EDU> wrote:

As a state agency, with state materials used by state employees - the occupational safety regulations do not require us to have or distribute MSDS, SDS or any data information sheets. Since we do not have any, we can not supply any to the LEPC.

Section 311 requires facilities that have MSDSs for chemicals held above certain

threshold quantities to submit either copies of their MSDSs or a list of these chemicals

to the SERC or TERC, LEPC, and local fire department.

As a side note, part of our campus is in the city, and part is in the county. Two different emergency management systems and two sets of regulations and policies.

Ed

Edward M. Movitz

Research & Environmental Compliance Officer / FSO

The University of Mississippi

Laboratory Services

100 Health and Safety Building

P.O. Box 1848

University, MS 38677-1848

U.S.A.

O:+1-662-915-5433 | F: 662-915-5480

movitz**At_Symbol_Here**olemiss.edu | www.olemiss.edu | Laboratory Services Web Site

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From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Sent: Friday, March 23, 2018 1:44 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] SDS requirements

A quick question, perhaps:
Am I correct that SDS's are required only by OSHA to support employer's safety programs for their employees. That is, if there is no employer-employee relationship, hazard information doesn't need to follow OSHA format requirements?

The reason I ask is that I know, for example, EPA requires MSDS's be supplied to LEPCs and emergency responders upon request. Of course, as with any EPA regulation, state and local interpretation and enforcement practices vary widely.

Thanks for any insight on this.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

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