SDS (Safety Data Sheets) Records - When and how long?

Hello Everyone and Happy Friday,

I'm setting up a HazCom program and starting to prepare for going BS 18001 certified. I'm having a problem finding the information on when and for what do we need to keep SDS's records.

We only have 4 chemicals we purchase and keep on site to sell or use in assembly. Gear oil and hose lubricants (water based, env. friendly).

What about other substances like WD-40, lithium grease, etc.? (all quanities under a quart)

How do you handle lets say if engineering brought into the facility a pint of lubricant to test with?

And how long do you keep SDS's records?

Any help or a point in the right direction of were to locate this information would be great. I have found some information on the OSHA websites but no specific info. on quantities or what is excluded from having to keep records.

Thank you
Griff23

I do not believe there is any quantity limit. A drop of some chemicals can be very dangerous. I am no expert but I think you would need MSDS for all chemical agents in case someone gets some in their eyes or skin.

29CFR 1910.1200 will tell you everything you need to know as well as the guidance you'll find on the OSHA website.

Hi !

Yes indeed you must comply with the OSH regulations of your country, but OSH regulations are the basis for the occupational risks pr?vention, not the end.

Whatever quantity and duration of using a substance or mixture the chemical OSH procedure must be the same: the SDS and the proposed method of use should be the basis for risk assessment of the project (simple test or industrial process ...).

What will change depending of the size of a chemical project is the size of the preventive provisions we decide, more or less important, strong or durable ...

Then (even for a simple test) it is useless to archive this "experience" (the SDS and the using caracteristiks). You can use these datas if a similar projet later appears or if legal problems then arise for example).

Bye.

When reviewing requirements under 29CFR 1910.1200 it's important to understand the difference between manufacturer and user.

As per 1910.1200(b)(4)(ii), if you obtain chemicals for use at your site, even temporarily or on a trial basis, people who could be exposed to the chemicals need to have access to the information a Safety Dada Sheet provides "during each shift" and 1910.1200(b)(4)(iii) directs you to provide employee training on the program. It makes sense to only keep up-to-date SDSs for currently used chemicals immediately available, but you should keep a history file of everything for research purposes. Keeping them current shouldn't be difficult because I see very little changes in MSDS over time, but I suggest a periodic review of these documents of external origin anyway.

If you only have a small number of such chemicals, I would keep it simple and just post a binder with them in an area where employees on each shift can have easy access. Some people use stations and binders like this commercially available example, but that's not needed as long as everyone who might need to read the SDSs know where they are, can access them on their shift (I would put one in their work area or some place easy to get to but hard to get lost) and understand how to use them. Keep it simple.

It's important that everyone who would be obtaining a chemical is involved with your HAZCOM process in that they tell you of their plans, ideally before they purchase the stuff so you can avoid getting something really nasty if a more friendly alternative is available. Again, keep it simple.

29 CFR 1910.1200 doesn't talk about records.

I hope this helps!

Under 1910.1020, the MSDS is considered a record and as per 1910.1020(d)(1)(ii)(B), "need not be retained for any specified period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least thirty (30) years...."

Trust me, if someone is brave enough to play silly games with OSHA they can toss the old MSDS's (or SDS as they are now known). The easiest way to retain information about chemicals used in the workplace is the MSDS.

Records for safety and environmental go way, way beyond what might be expected, especially when you could wind up in the defendants chair.

Griff23 said:

Hello Everyone and Happy Friday,

I'm setting up a HazCom program and starting to prepare for going BS 18001 certified. I'm having a problem finding the information on when and for what do we need to keep SDS's records.

We only have 4 chemicals we purchase and keep on site to sell or use in assembly. Gear oil and hose lubricants (water based, env. friendly).

What about other substances like WD-40, lithium grease, etc.? (all quanities under a quart)

How do you handle lets say if engineering brought into the facility a pint of lubricant to test with?

And how long do you keep SDS's records?

Any help or a point in the right direction of were to locate this information would be great. I have found some information on the OSHA websites but no specific info. on quantities or what is excluded from having to keep records.

Thank you
Griff23

Click to expand...

I'm in Canada, and these rules are clearly spelled out in our OHS laws.

Where I work, Engineering is not permitted to bring in ANY controlled product without it going through Receiving. Receiving is to ensure that an MSDS has been provided by the manufacturer before accepting the shipment. If there isn't one, the courier has to remove it from the premises.

If a controlled product is on the premises, an MSDS sheet no older than three years must be made available.

Doesn't matter if the product is environmentally friendly, water-based, or under a quart - if it meets the definition of a controlled product, you need an MSDS. BTW, WD-40 is highly flammable and is mildly toxic (aspiration hazard).

Here in Canada, the six classes of controlled products are:

Class A - Compressed Gas
Class B - Flammable and Combustible Material Class C - Oxidizing Material
Class D - Poisonous and Infectious Material Class E - Corrosive material
Class F - Dangerously reactive material

I cant speak for any other jurisdiction but In Australia an MSDS or SDS as they are referred to these days must be immediately available for the user and emergency services to consult. This means they have to be in close proximity to the substance.

MSDS's must be renewed every 5 years as manufactures can change the formulation of the substance and therefore the physical and chemical properties of the substance which may affect reactivity, toxicity and other relevant characteristics.

The SDS is used as the basis for the risk assessment, handling, storage, safe use, identification of PPE etc. A risk assessment must be carried out on each substance.

The employer must have an SDS for each and every chemical. For example, for petrol (gas in the US) they must have a SDS for each brand and each type. The MSDS for unleaded petrol is different to that for super grade.

One oil company's petrol is different to another oil company's petrol and therefore they have to have an MSDS for each brand and type. All petrols have the same UN number but you cannot just have an SDS for the UN number alone.

If anyone is looking for software to manage chemicals with Chemalert is a very popular program in Australia, you buy an annual subscription and the program works of Chemalert servers.

Risk assessments can be done in Chemalert

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cheers

Hello !

Kgott, I don't completly agree with you regarding two point :

- I am not ok to say "MSDS's must be renewed every 5 years" because there is no "periodicity" for the validity of a SDS. For the user to wait 5 years to verify if a FDS is still valid seems too long for me. Especially as normally if the supplier updates a SDS he must notify his to its customers (provide the new version).

- To carry out risk assessment "on each substance" is not very relevant. For risks assessement it's imperative to analyse the processtoo ! So if I have still assessed risks of a first process using le substance ou mixture A, a second different process with the same chemical A needs to do a second risk assessment ! So the target of chemical risk assessment is not the chemicals but the couples "chemical + process". So I say "A risk assessment must be carried out on each substance-process". "Chemical A + process 1" is different of "chemical A + process 2" and "Chemical A + process 1" is different of "chemical B + process 1". I think this approach is very important.

Bye.