GHS compliance - Are we are required to provide an SDS?

R

RandyCissner

#1
I am trying to get an understanding on whether or not we are required to provide an SDS under the new system. I work for an abrasives company making quick locks, flap discs, etc. We do not make the actual paper here, it is made overseas. We only assemble the products. No hazardous materials are used. None is corrosive in any way. I believe we are exempt under the "Articles" section, but I'm looking for clarification. We have never been required to use any hazardous labels at anytime. We provide the SDS sheets to customers from our vendors if requested so they can see what they have. We are just trying to make sure we are doing what is necessary. Any suggestions are appreciated.
 
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#3
Hi Randy, and welcome to the Cove.

Take this as on online forum response...not as a government or OSHA ruling...

To the best of my knowledge, no one is required to send an SDS with anything (odd but true).

The recipient is required to have an SDS on site and available to anyone exposed to potentially hazardous material. This has turned into a common habit of sending one to your customers...but I don't believe that is an actual requirement.

Bottom line, if your customers don't ask for them, and the materials are not hazardous, you're pretty clean.

As a "Distributor", if so classified, you have until 12/1/2015 to be GHS compliant. This gives you time to get updated SDS's from your vendors.

With OSHA..."better safe than sorry" is a good rule of thumb all the same.
I your place (and I am), I would ask my vendors for an updated GHS Compliant SDS...push the burden over to them.

HTH
 
R

RandyCissner

#4
Thanks for the replies, I appreciate it. I was able to get in touch with OSHA, and since we are not changing the chemical make up of the paper in or assembly process, and also since this is not a chemical or toxic to a down stream if exposed, we do not need to provide an SDS. We are only required to give the SDS from the vendor we get our sandpaper from. The companies we buy from are all overseas, and some are compliant, some are not. Some are working on them, some...not so much. That is the depressing part, when someone asks and you cannot provide an update because you are waiting on your supplier. The companies that were asking are the major catalogue distributors. But after the Industrial Hygienist from OSHA said we did fall under the "Article" exemption, it helped us greatly. Thanks again!
 
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