MSDS & EMS (Environmental Management System) Linkage

[Cheryl]

Next week we will be undergoing our EMS certification audit. During a final review of our D&D it was discovered that our MSDS files where not in compliance. We have a team in place who are contacted and updating the manuals as we speak, this process will be completed in time for the audit.

Question, should we be concerned with the WHMIS (or lack of) labels on the shop floor. We conducted a walk through of all our plants and made some considerable findings, mostly a lack of completed information on the labels. Will this short fall cause us any problems during our EMS certification audit? I'm not certain just how closely linked the EMS is with WHMIS, can you advise please?

[db]

Cheryl, are your MSDS (material safety data sheets) listed as aspects? Why do they enter into the picture? I'm not certain they need to be part of the audit.

[Randy]

The requirement to maintain MSDS sheets is an OSHA and not an environmental (EPA) one. Simply put, you must have an MSDS for every hazardous material that employees will use in the course of their work. It is a littel more complicated than this, but we'll stop here.

Among other things an MSDS may provide information as to proper emergency procedures, storage information, and disposal recommendations.

If your EMS specifies MSDS availability then you will need to make sure that you meet the requirements established in 29CFR 1910.1200 (Hazard Communication). For a better grasp of what you need to do go to www.osha.gov and look under the "Interpretations" link.

As for the labels on the top of the can...Does you company HAZCOM Program specify how hazmat is to be labeled? If it does, do what your program requires. Hazardous Materials labeling requirements are also specified in 29CFR 1910.1200 for both primary and secondary containers.

One question...has your safety manager/dude/guru/guy/etc. been invloved in the EMS program? If not...Why? If he/she has....why is this subject coming up so late?

Cheryl....you're going to have to look up the Canadian equivalent of the US regulations I quoted. I goofed...but the info is good for US companies. A good Canadian site is www.ccohs.ca (Canada's National Center for Occupational Health & Safety)

[Dean P.]

Cheryl,

Randy is correct in that the MSDS's provide the environmental information on your hazardous and non-haz materials. In order to determine what is hazardous, you need to refer to the MSDS, therefore, these need to be included as a record in your system. And lucky for you, in Canada we have a requirement that ALL MSDS's must be less than 3 years old. If you receive materials from Canadian sources, they must (should) send updated copies to you every three years. If, however, you receive materials from US sources, you typically have to get them to send a letter stating that your copy is the most current version (or some other type of confirmation from the supplier). They usually don't revise their dates for you (us).

As for the labeling requirement, it is absolutely imperitive that your H&S person be intimately involved with the EMS. There is so much overlap in the two systems and with OSHA and EPA, it would almost be easier to make it an EH&SMS (almost).

Finally, since your auditors will most likely be Canadian, they will almost always look at labeling and MSDS's while in the plant, because they know that this is always a relativley weak area in all facilities (in my experience). They also know which legislation applies to these areas (including OSHA, Transporation of Dangerous Goods, certain Handling Codes, as well as Hazardous Waste classifications) and can cite you under 4.3.2, if anything. Hope this helps, and good luck!!

[Cheryl]

Thank you. Your information has prompted us to postpone our audit for another couple of months. This should give us time to clean up some of the weaknesses and tighten up our policies concerning MSDS/WHMIS prior to our EMS audit. Again, I really appreciated your help and quick responce to my question.

[Manoj Mathur]

Around 3,00,000 Material Safety Data Sheets Database is available on this site. You may download the MSDS freely from it.

http://msds.pdc.cornell.edu