Do MSDS's (Material Safety Data Sheets) need to be controlled. If yes, HOW?

S

Shannon - 2007

#1
I'm sure this has been asked before, but I need to ask the question again.
Do MSDS's need to be controlled?
And if yes, what is the best method for controlling this large collection of external documents, that actually adds value to the plant, and is fairly easy to manage.
I'm looking for a real control method, that is sustainable.
:frust:
 
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Randy

Super Moderator
#2
1st try to minimize the number you maintain. Many times organizations maintain an MSDS for a "consumer commodity" material, resulting in documentation overkill.

You next need to evaluate employee access to MSDS's. CalOSHA has an undefined time requirement of 15 minutes (I've been down the CalOSHA trail more than once when I was doing EHS in CA). Develop a system that enables employees to "readily" access an MSDS, whether electronic or hard copy.

I've found the simplest method is to generate an alpha-numeric system with each material having a unique number. The alpha part can be used to identify the type or area usage (if only used in 1 area) and the numeric is self explanatory. Materials used in process or by employees have to be labeled, so as part of the routine each material, lets say can of paint or bottle of giz, before it is dispensed or issued, is tagged with the unique number. Presto, bingo, there it is.

File your MSDS's under the unique numbers (set up a spreadsheet maybe) and there you go.

I'm currently using a similar system on my hazmat here. The information I gather from the unique identifiers provides me what I need to do my monthly mass balance calculations for my Title V permit, TIER II reports, and SWPP management.
 
B

Bill Pflanz

#3
Randy,

Your response for controlling MSDS was great but how do you verify that you have the most recent version. The supplier may have a responsibility to provide an MSDS but they do not have to supply it with each shipment. What if the MSDS is updated but never sent?

The only reason I asked is that I do not remember a very robust system for sending MSDS when I was in the chemical industry. Assuming you actually use the MSDS, an inaccurate sheet is just as bad as none at at all. Besides having a great filing system, what evidence do you have that the MSDS are doing more than allowing you to complete your monthly reports?

I apologize if it sounds like a rant, but after seeing them sent out for years, they don't seem to even have the value of at least toilet paper.

Bill Pflanz
 

Randy

Super Moderator
#4
You're right! Most MSDS's will scratch your butt if you try to use them for TP. :mg:

There are numerous subscription services, software programs and other types of services that will either track MSDS's and keep them updated or let you know that changes have possibly been made...You know what? They are ultimately a waste because in the end, it is the organization where the final responsibility rests. A regulator doesn't give a hoot in h3ll about all that gibberish because responsibility and accountability cannot be transferred by contract to someone else.

Remember my article on communication and breeching the wall? Here's the wall staring the manager of the MSDS data in the face.

When people get new stuff they need to say "Hey I got some new stuff, do I need to do anything else?" Somebody has to tell someone else to always request the most current MSDS when purchasing new and previously purchased materials. How about telling someone "Hey, we got some MSDS's in with the last delivery of whiz-bang", instead of tossing them. The list can go on.

Our purchasing department automatically asks for an MSDS for everything we purchase. They normally ask that it be faxed or emailed and then they bring it to me. An MSDS (and CPDS for quite a few things) on some material has to be obtained, reviewed and approved by me before the item is purchased by us or supplied by a customer. I have turned down customer supplied material and we have even lost some work through this process. Can you imagine, the lowly EHS guy saying some work can't be done and no argument, and the work goes elseware?

You can't depend on an MSDS to be sent, but you can assure that it is asked for and that material is not utilized until it is in hand.
 
S

Shannon - 2007

#5
Thanks Bill for asking the questions that I had concerns about.
Thanks Randy for the great advice.
I still have questions though. I can hear the auditor, in my head, asking me for objective evidence that the MSDS's are always requested. What could I provide to him/her that would prove this?
 

Randy

Super Moderator
#6
The only thing I can give you is that you be able to show that requesting an MSDS is a business practice and maybe a procedure or something to back it up. The availability od MSDS's should also provide a certain amount of objective evidence as well. A real good piece of evidence is if somewhere within your purchasing or procurements agreements/contracts you have language stipulating that all suppliers must supply a current MSDS with all materials shipped and delivered to you.
 
B

Bill Pflanz

#7
An even better question would be that we got this new stuff and where is the MSDS so I can see if we need special procedures to handle it safely.

Since you are required by law to have MSDS available to the workers, proving to an auditor that you "requested" it is irrelevant. It is either available or not. It is about equivalent to using ignorance of the law as a defense when you break a law. I would hope the auditor would never pose the question or the nonconformance that way.

Randy, now we know how tough you really are or how cheap your company is. :bonk:

Bill Pflanz
 
J

jaimezepeda

#8
Shannon said:
What could I provide to him/her that would prove this?
Could you add some wording to the Purchase Order forms that essentially asks for an MSDS when applicable?

Jaime
 

Randy

Super Moderator
#9
You can add wording that asks for a picture of their momma if you want. It's your form. :lol:

Asking for it in documentation though is meaningless if you don't back up non-compliance with action. That's the big catch! Many organizations or people in them don't want to appear "mean" so they blow things off because they don't think that is realy important.

Right now where I sit, the absence of an MSDS/CPDS can be worth $300K+ (no questions asked and no explaination required with no appeal) and an additional $2K per day since sometime in 2001. I have my MSDS's and corresponding CPDS's.

The management of regulated documents like an MSDS has got to be approached as seriously as that of managing financial records and product design documents. Marketing and sales bring work in, production gets work out, EHS keeps the doors open.
 
C

C Emmons

#10
We post ours on our company intra net Safety Page. Somehow our IT department has this set up so that the systems checks the manufactures site for current revisions once a year. Dont know how practical it is for some, but it works for us.
 
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