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Subject: Re: [DCHAS-L] SDS for Hand Sanitizer
Date: Friday, April 3, 2020 at 10:58:37 AM
Author: "Alexander, Brian (US)" <brian.t.alexander**At_Symbol_Here**BAESYSTEMS.COM> 		Next by Date:
Subject: Re: [DCHAS-L] SDS for Hand Sanitizer
Date: Fri, 3 Apr 2020 11:24:11 -0400
Author: Joseph Smith

From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Subject: Re: [DCHAS-L] SDS for Hand Sanitizer
Date: Fri, 3 Apr 2020 11:02:45 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 8184A7E4-C984-4973-98CA-99091663EF88**At_Symbol_Here**ilpi.com
In-Reply-To


Assuming it is not classified by the FDA as a drug (which I doubt), the short answer is yes, an SDS is required for this intended purpose.

While consumer products packaged for retail consumer production are exempt, a consumer product used in an occupational fashion that exceeds normal consumer use requires one.  For example, you do not need an SDS for Windex in your workplace if you clean windows with the same frequency as a consumer, but if your job is a window-washer, then you would need one.  Arguably, a medical worker will exceed normal consumer use of hand sanitizer.  See our SDS FAQ question about exemptions for consumer products here: http://www.ilpi.com/msds/faq/partb.html#consumer 

MSDSOnline has a blog post on this topic: https://www.msdsonline.com/2020/03/19/chemicals-in-the-workplace-covid-19-cleanup-considerations/ 

This assumes that OSHA has not created a temporary exemption of some kind.  I do not see any evidence of this. I did find this memo on enforcement regarding N95 fit testing: https://www.osha.gov/memos/2020-03-14/temporary-enforcement-guidance-healthcare-respiratory-protection-annual-fit which may be of interest to your target audience.

Best wishes,

Rob Toreki

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On Apr 3, 2020, at 9:44 AM, Steven Nelson <steve.nelson**At_Symbol_Here**AUBURN.EDU> wrote:

Are organizations which produce and distribute the hand sanitizer produced under FDA temporary guidance required to supply a SDS? Our School of Pharmacy plans to produce hand sanitizer for our medical clinic. Labeling would be in accordance with the FDA guidance for temporary compounding of alcohol based hand sanitizer.  But do they need to create a SDS to distribute with the product?

https://www.federalregister.gov/documents/2020/03/23/2020-05959/policy-for-temporary-compounding-of-certain-alcohol-based-hand-sanitizer-products-during-the-public

Steve Nelson
Auburn University, Risk Management and Safety

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