Are MSDS sheets or books a part of ISO9001 or QSI audits?

[RTerranova]

Hi all
Q) I need to know (100%) if the MSDS sheet or books, if they are part of the ISO or by the QSI audits.

1) By the best of my knowledge, is yes to this the MSDS sheets are part of the ISO accreditation and they need to be audit.

2) By the standad 4.2 (all)

3) This can be documents of external origin by ISO Standard (sec 0.4) and 4.2.3 sec (f) document of external origin

etc..................

yes we are receiving the material datasheet and the MSDS documents for the Chemical we are using

any one have a input to this.

 

[fuzzy]

Re: The MSDS sheets or books part of ISO9001 or by QSI audits?

Hi all
Q) I need to know (100%) if the MSDS sheet or books, if they are part of the ISO or by the QSI audits.

1) By the best of my knowledge, is yes to this the MSDS sheets are part of the ISO accreditation and they need to be audit.

2) By the standad 4.2 (all)

3) This can be documents of external origin by ISO Standard (sec 0.4) and 4.2.3 sec (f) document of external origin

etc..................

yes we are receiving the material datasheet and the MSDS documents for the Chemical we are using

any one have a input to this.

I will state to my knowledge, "No". I believe that this fear has been discussed in other threads, and I know I have covered the topic with my own registrar, and the answer was: not within the scope of ISO 9001:2000.

Don't know what a QSI audit is ... can you explain?

So for Item 1: NO

Item 2: NO there is no requirement listed here; these are very general requirements for a QMS.

Item 3: He11 NO; this is saying almost the opposite There are no requirements for other systems in the 9001 Standard but these other types of systems could be integrated into the 9001 framework should you chose to do so. But this would still not make them auditable IMO. NO scope under 9001 = No audit

PS: Welcome to the Cove, RTerranova!!

 

[Jen Kirley]

Re: The MSDS sheets or books part of ISO9001 or by QSI audits?

Welcome RTerranova!

I agree with Fuzzy. However, such agreement could be misunderstood into a belief that MSDS are not needed to show conformance to the system and standard. That's not necessarily the case.

In questions like this it's worthwhile to look at the reasons for having the MSDS. OSHAS 18001: 4.3.1 directs us to identify relevant risks and plan for them, and 4.4.2 directs us to ensure employees are aware of the potential consequences of departing from specified operating procedures. 4.3.2 directs us to comply with legal requirements, which includes the Right To Know law that it the typical reason for aquiring MSDS.

The MSDS aren't auditable by themselves; however, having a process for identifying risks and then providing needed information (such as MSDS) if the risks warrant it is auditable. While one missing MSDS might not raise much of a problem, having no process to decide if they're needed and thus having none (or half, perhaps) could be a significant problem.

A final note: I'd also be cautious if having a bunch of 10-year-old MSDS. I would feel more comfortable working with a system that includes a timely review for the information's continued relevance.

 

[fuzzy]

Re: The MSDS sheets or books part of ISO9001 or by QSI audits?

Welcome RTerranova!

I agree with Fuzzy. However, such agreement could be misunderstood into a belief that MSDS are not needed to show conformance to the system and standard. That's not necessarily the case...

the MSDS aren't auditable by themselves; however, having a process for identifying risks and then providing needed information (such as MSDS) if the risks warrant it is auditable. While one missing MSDS might not raise much of a problem, having no process to decide if they're needed and thus having none (or half, perhaps) could be a significant problem.

Jennifer, could you clarify the part where you say the process for risk ID is auditable, and by whom, to what std. (OSHAS 18001 by OSHA?) ? I believe the OP asked about this issue within the 9000:2K & QSI (still undefined to me) frameworks.

 

[Scott Catron]

Re: The MSDS sheets or books part of ISO9001 or by QSI audits?

Just a couple nits - yes I'm being pedantic...

4.3.2 directs us to comply with legal requirements, which includes the Right To Know law that it the typical reason for aquiring MSDS.

MSDSs are actually a part of the OSHA Hazcom regulation - see 29CFR 1910.1200(g). 'Right To Know' is EPA language - usually associated with companies' Toxic Release Inventory reports.

A final note: I'd also be cautious if having a bunch of 10-year-old MSDS.

..but remember you have to keep a 30-year history of possible chemicals employees may have been exposed to - see 29CFR 1910.1020(d)(1)(i).

 

[Jen Kirley]

Re: The MSDS sheets or books part of ISO9001 or by QSI audits?

Jennifer, could you clarify the part where you say the process for risk ID is auditable, and by whom, to what std. (OSHAS 18001 by OSHA?) ? I believe the OP asked about this issue within the 9000:2K & QSI (still undefined to me) frameworks.

I did find it in 18001, 4.3.1. 18001 is not a strong standard so there is not a crystal clear requirement. I'll have to get back at my desk to do better than this.

 

[Randy]

Re: The MSDS sheets or books part of ISO9001 or by QSI audits?

Material Safety Data Sheets would only be system documents if they were identified as such by the organization for some reason, or within a customer requirement (which would require the organization to identify them as system documents also).

Are MSDS's automatically QMS documents....NO! I don't look at them during QMS audits unless they have been specifically identified as system documents (normally of external origin)

 

[Jen Kirley]

Re: The MSDS sheets or books part of ISO9001 or by QSI audits?

Just a couple nits - yes I'm being pedantic...

No problem, we should be accurate here!

MSDSs are actually a part of the OSHA Hazcom regulation - see 29CFR 1910.1200(g). 'Right To Know' is EPA language - usually associated with companies' Toxic Release Inventory reports.

Yes, I think I may have been confusing Federal Hazard Communication Act with state Right To Know law. See here for more information: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FACT_SHEETS&p_id=151

...but remember you have to keep a 30-year history of possible chemicals employees may have been exposed to - see 29CFR 1910.1020(d)(1)(i).

Yes! Do keep a record of the risks personnel have been exposed to; just keep the risk management information up to date. I also vote for hanging onto MSDS used during the time of exposure. It could help to show why your programs looked as they did or changed over long periods. As we learn more about human reactions to come chemicals over long periods, PPE such as respiratory protection has changed somewhat.

 

[Jen Kirley]

Re: The MSDS sheets or books part of ISO9001 or by QSI audits?

Randy's right of course. The only reasonable reason for MSDS crossing systems is to show conformance with something like Section 6.4.2 of TS 16949, regarding providing a means to minimize potential risks to employees.

 

[Duke Okes]

Re: The MSDS sheets or books part of ISO9001 or by QSI audits?

If purchase orders require that suppliers provide MSDS sheets, then their existence could be auditable under ISO 9001. Their content and how the organization protects employees, etc. would not be.