Control of MSDS (Material Safety Data Sheets) - Document Control required?

[qalsang]

We are displaying MSDS at the points where chemicals were used.
How should MSDS be controlled??
Is it necessary to classify MSDS as controlled documents?

 

[Dr. L. Ramakrishnan]

Hi

Material Safety Data Sheets are not meant only for displaying at places where chemical substances are stored; MSDS are a set of standard quick reference documents for properties of materials and chemicals. Useful information on compatibility with other substances, risk of fire and explosion, storage, first-aid, waste disposal etc., are provided in MSDS. MSDS contain quite a few properties that do not change or/which are fundamental (e.g. boiling point, flash point etc.). There are properties like TLV (C or TWA) LD50, BEI etc., which are important and change as and when new information is made available on the substance in question.(e.g. TLV (TWA) of mercury has come down from 0.05 mg per cu.m. to 0.02 mg per cu.m. in the last 20 years). Hence it is important to review and update the MSDS periodically (in some countries maintaining MSDS is a mandatory requirement under legislations like the Factories Act; in those cases the updating becomes a requirement under 4.3.2 anyway). As the information contained in MSDS is used by different functions, it is necessary to control the document to ensure that only the current information available at relevant functions and is used to avoid risk to the organization.


With kind regards,

Ramakrishnan

 

[harry]

Also look at the discussions in the first 2 posts of the 'Similar Discussion Threads' box below - just scroll down the page.

 

[Big Jim]

MSDS sheets are documents of external origin and fall under element 4.2.3 f. In most cases, they would need to be controlled.

It is not necessary to list all of the sheets individually. If you have a "List of External Documents" show the MSDS sheets as an MSDS binder and show where the binder is kept.

 

[SteveK]

As an addition to the advice given & FYI, in the UK and I assume elsewhere, legislation requires that the supplier of a chemical must automatically supply a new MSDS if it is ammended or issue a replacement on an annual basis (even if it has not changed). So that is one control mechanism.

 

[bobdoering]

As an addition to the advice given & FYI, in the UK and I assume elsewhere, legislation requires that the supplier of a chemical must automatically supply a new MSDS if it is amended or issue a replacement on an annual basis (even if it has not changed). So that is one control mechanism.

I think a better way to phrase it is "make available". MSDS maintenance - long before ISO14001 - has been a US mandate, and treating them as controlled outside standards is likely your best bet. They are nasty, tricky documents to control - do you file it by the supplier name, by the chemical, by location used, part number, by the brand...etc.? The idea is to be able to look up the material fast in case of an emergency. That is why an index is handy. A yearly review of MSDS, with either a review of websites for updates or letters requesting updates would be a good idea.

 

[Stijloor]

I think a better way to phrase it is "make available". MSDS maintenance - long before ISO14001 - has been a US mandate, and treating them as controlled outside standards is likely your best bet. They are nasty, tricky documents to control - do you file it by the supplier name, by the chemical, by location used, part number, by the brand...etc.? The idea is to be able to look up the material fast in case of an emergency. That is why an index is handy. A yearly review of MSDS, with either a review of websites for updates or letters requesting updates would be a good idea.

Excellent points!

The list of MSDS's could include links to the suppliers' websites for quick verification.

Stijloor.

 

[Randy]

MSDS sheets are documents of external origin and fall under element 4.2.3 f. In most cases, they would need to be controlled.

It is not necessary to list all of the sheets individually. If you have a "List of External Documents" show the MSDS sheets as an MSDS binder and show where the binder is kept.

Hey Jim, this is ISO 140001 not ISO 9001 and the requirement falls under 4.4.5f ...ensure that documents of external origin determined by the organization to be necessary for the planning and operation of the environmental management system are identified and their distribution controlled, and...

As for the actual control, the way that you have deemed to be the most appropriate and effective in meeting the control requirements is the proper way.

The MSDS is and of itself an Operational Control (4.4.6) of sorts because they normally contain information which if not followed could lead to regulatory non-compliance and adverse environmental impact. So in essence they are a type of a procedure...very loosly , but it can be argued.

Controlling an MSDS as a record may be appropriate as well.

 

[bobdoering]

It is not necessary to list all of the sheets individually. If you have a "List of External Documents" show the MSDS sheets as an MSDS binder and show where the binder is kept.

Although not mandatory, it is darn handy, as well as the last time they were verified. That way, if you get new materials in, you can easily verify if you need to add the sheets to the books - or if they are already there...

Also, without some kind of index, they can be a bear to root out of the binder(s).