Company Name on IMDS Sheets - using ours instead of our distributor?

S

srebo70

#1
My company is a manufacturer and distributor. We maintain our IMDS sheets for the products we make in house, but when a customer of our distributed product that we source requires the sheets, we have an issue.

We can obtain the sheets from our suppliers, but being that we sell to other distributors, we do not wish to have our suppliers name on the sheets.

Since we are the company selling the product to the distributors here, can we provide the sheets to our customers with our own title block, eliminating the that of our suppliers?

If this is in the wrong area, please move to the correct forum!

Thanks for any input!
 
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Ron Rompen

Trusted Information Resource
#2
Re: Name on IMDS Sheets

My own opinion on this, and what I have done in the past, is that the product you are supplying is made up of many sub-products. Your responsibility is to report the ENTIRE composition of the supplied product. Whether you choose to do it by referencing your sub-suppliers IMDS sheets, or by creating your own, doesn't really matter. The important thing is that everything is reported accurately.
 

Kales Veggie

People: The Vital Few
#3
Is the OP referring to IMDS or MSDS? There are not the same.

For both, I would be very careful.

For MSDS, there are potential legal liabilities involved (incorrect information, update of information, etc)

For IMDS, you are taking responsibility for accuracy by recreating the MDS in your account and submitting it to your customer. You are entering information that you have not verified and maybe can not verify. Your supplier might not approve of this either (putting your company name with their product information)

I think in both cases you are taking huge risks and exposing you and your company to legal liabilities.

I believe in both cases the information should come from the manufacturer, so accuracy can be guaranteed and responsibilities are clear.
 

Kales Veggie

People: The Vital Few
#4
Re: Name on IMDS Sheets

My own opinion on this, and what I have done in the past, is that the product you are supplying is made up of many sub-products. Your responsibility is to report the ENTIRE composition of the supplied product. Whether you choose to do it by referencing your sub-suppliers IMDS sheets, or by creating your own, doesn't really matter. The important thing is that everything is reported accurately.
I think that you are taking a huge risk. How do you know that the information that you enter is accurate and what about updating?

It does matter, in my opinion.

(On occasion: If a sub-supplier can not enter or does not want to enter an MDS, I have used their material certification that was included with the PPAP to create the MDS for that material.)
 

Ron Rompen

Trusted Information Resource
#5
Kales has raised a valid point, and one which I did not fully address at the time.

Part of the issue is, of course, the material(s) that you are using in your product. In my case, it was generally low carbon steel, occasionally some plating or nylon encapsulation, things of that nature. In all cases, less than 6 products to be identified on the IMDS sheet, and all of them easily researchable on the internet.

In a more complex product (such as my current employer) it would become more difficult. Many of the products can still be researched on the internet, or can be discovered in-house, but some proprietary products would have to come from your supplier. It all depends on what you are making, and how complex it is, I guess.
 
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