Safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual
hazardous chemicals. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in their work area(s).
I think its not in our best legal interest to substitute SDSs from one manufacturer for another, even if we think one is better than another. If an employee were to report an exposure, and the formulation or information available were to
differ than the manufacturer, then this substitution might affect who is determined to be the "responsible party."
If you are an end-user, it is your responsibility to use and keep the latest SDS version - and ensure that it is easily accessed by all employees. There is no harm in keeping an SDS from each manufacturer.
However, updating SDSs all the time can be burdensome. OSHA does allow manufacturers to create an SDS that covers multiple products, but I am not certain about what OSHA says about end-users substituting SDSs. I have found many SDSs lacking in information
or no longer available, so I keep the old MSDS as well as newer/better SDSs with updated information so both are available to employees. No fun, but I want to cover my bases. Any suggestions on a better approach or interpretation about what OSHA says?
I should clarify that the inventory is mainly used by researchers and we do used the newest manufacturer's SDS for all new chemicals coming into the system. For older bottles however is where I run into these problems and I upload the best
SDS I've determined for that particular chemicals because I get "edited" SDS back from the company that bought the older company. I also make notes on each chemical entry informing the researcher where I got all the hazards. (The inventory system allows us
to enter all the GHS hazard so all the classifications are written out and researchers see them right away).
Here's an example of a respond I've gotten when I told then I needed an SDS not a MSDS.
This is the SDS. We just didn't take the M off. An MSDS is the same as a SDS. Sorry if that confused you.
What I sent you was the Material Safety Data Sheet. Which is in essence a Safety Data Sheet.
So you can see the situations where I need to "pick and choose" the best SDS for chemicals and not go off the manufacturers. Sometimes the chemical is so old that they don't have GHS classifications.
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
On Behalf Of Monona Rossol
Sent: Tuesday, June 11, 2019 1:48 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] What is happening to the GHS SDS?
I'm not answering for Jeff, but I sent people to Sigma, not to put their SDSs in the book instead of the manufacturer's SDS, but to put the Sigma SDS there for the
correct data along side the junk from the US manufacturer. I kind of second opinion SDS.
Monona
-----Original Message-----
From: Yaritza Brinker <YBrinker**At_Symbol_Here**FELE.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Tue, Jun 11, 2019 11:46 am
Subject: Re: [DCHAS-L] What is happening to the GHS SDS?
I've always been under the impression that you are required to have the newest SDS on the book. However, your job hazard assessment can (and should) include information
from other sources.
If I'm wrong, please let me know.
Thank you,
Yaritza Brinker
260.827.5402
-----Original Message-----
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
On Behalf Of Jeffrey R. Cogswell
Sent: Tuesday, June 11, 2019 10:35 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] What is happening to the GHS SDS?
** External Email **
Hello Everybody
I've been reading the threads about GHS SDS and wanted to share my observations.
It's good to know I'm not the only one seeing issues but I think one reason might be because of merger of some companies, especially Sigma and Millipore. It's interesting as I'm seeing more details for PPE to be worn but some chemicals that had warnings in
older versions are now "NO GHS Hazards" or don't meet hazard reporting.
I wish there was access to all previous "versions" of SDS sheets especially from Sigma Aldrich.
I'm currently in the process of inventorying the entire campus and each chemical I barcode has an attached SDS in the system. In some cases I feel that an older version is better than the latest one and have opted to not update it. I have also set requests
to companies asking for an SDS sheet because I couldn't find it online. After a long wait I'm given a MSDS with the M removed so I needed to find alternatives.
The complete elimination of NFPA and HMIS I feel are not the best decision for SDS. Our inventory program uses NFPA for building fire codes and for training with our Fire Dept. incase of an accident in the lab. First responders still need these codes and I
feel should be provided. These have been in the past but are disappearing from SDS.
All updated SDS from MillipreSigma are eliminating NFPA's and I've only been able to consistently find them at ThermoFisher.
Conflicting hazard information has always been an issue but I have a problem with eliminating safely information altogether, that has been previous available.
-Jeff Cogswell
-----Original Message-----
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
On Behalf Of Yaritza Brinker
Sent: Tuesday, June 11, 2019 9:41 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] What is happening to the GHS SDS?
Monona,
Even though GHS is really good, the reality is that NFPA and HMIS labels are easier for the common worker. If you are standing in a manufacturing plant looking at drums and totes of chemicals, then NFPA and HIMS labels are simply easier to read. Some employers
choose to add an NFPA or HMIS label to their containers on arrival.
I'm personally partial to HMIS labels because it includes a letter for the PPE type required. This is a good reminder for people like myself who run different types of tests with a wide range of chemicals and therefore wide range of risks.
Thank you,
Yaritza Brinker
260.827.5402
-----Original Message-----
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
On Behalf Of DCHAS Membership Chair
Sent: Saturday, June 8, 2019 1:28 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] What is happening to the GHS SDS?
** External Email **
From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
Re: What is happening to the GHS SDS?
I'm hoping someone can tell my why, after we finally have a good system of describing acute and chronic toxicity with the GHS dose-response Categories, I'm suddenly seeing the misleading dumb old HMIS one number toxicity system showing up even on the new Sigma
SDS for Cyrene.
This is really depressing.
Monona Rossol, Arts, Crafts & Theater Safety.
---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at
membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
Electronic Transmission Confidentiality Notice The information contained in this electronic transmission is private, confidential, the property of the sender, and intended for the use of the recipient(s), only. If you are not the addressee, any disclosure,
copying, distribution or use of this information for any purpose is strictly prohibited. If you have received this information in error, please notify the sender,
YBrinker**At_Symbol_Here**fele.com, immediately by e-mail and then delete this message.
Thank you.
[FE.EN.1]
--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at
membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at
membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at
membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
