MSDS process audit - Can any one give idea for checklist of the same

[Moaaz0911]

Dears,

As company, We have a MSDS process which to be audited during incoming days.

Could any one give idea for checklist of the same.

The fact is MSDS generated by company is not updated as per GHS but the supplier MSDS is updated, what is the impact on audit findings

 

[Jen Kirley]

Welcome to The Cove!

I think of MSDS (now SDS) as documents of external origin. As such, the organization is not responsible for controlling their revision (content) but is expected to provide up-to-date information to personnel as needed. What do your procedures say about them? ISO 45001:2018 requires (7.5.3) that "Documented information of external origin determined by the organization to be necessary for the planning and operation of the OH&S management system shall be identified, as appropriate, and controlled." Are SDS necessary for the planning and operation of your OH&S management system?

There were good reasons for MSDS to move to their new format. They used to be so different - some needed a PhD in Chemistry to understand, others left out large sections of information and said "proprietary." The new format is not perfect, but I think it is an improvement.

The task of keeping these up to date is thankless, and can be enormous depending on the number and type of chemicals you have. Some manufacturers provide a copy of SDS with every bulk shipment, while others must be researched on line or requested by telephone. This can become awkward as manufacturers go out of business, are acquired, change their names etc.

As an auditor I have issued nonconformances for failure to keep these documents current, but largely did so if the organization claimed to have control of it and I found truly ancient MSDS... I am talking about 1992 vintage. A lot can change in that much time, based on updated medical understanding of effects some of these chemicals can have.

As far as checklists go... are you required to keep a list of chemicals you store/use on site? If so, that is a place to start. I would even consider using such a list to periodically check if these chemicals have expired, or are even still needed at all, are stored properly etc. That is a big effort too, but it can occasionally be worthwhile. I would not feel the need to use anything more elaborate than a matrix that lists the chemicals, and has boxes to indicate with X the found acceptable criteria. For those that do not conform, I would indicate with a circled 1, 2, 3 etc. and indicate the meaning of these at the bottom of the page. Simple methods are good for a job like this.

I hope this helps!

 

[Moaaz0911]

Firstly thanks for your reply..


Let me clarify some things; my company is producing chemicals and status is
Raw material MSDS which received from suppliers is updated as per GHS.

But MSDS for products which generated by my company is not updated as per GHS...

What is the impact for that form audit side of any another side ...

Thanks in advance.

 

[Jim Wynne]

Firstly thanks for your reply..


Let me clarify some things; my company is producing chemicals and status is
Raw material MSDS which received from suppliers is updated as per GHS.

But MSDS for products which generated by my company is not updated as per GHS...

What is the impact for that form audit side of any another side ...

Thanks in advance.

What type of audit are you anticipating? What are the documented requirements for the issue that concerns you?

 

[Moaaz0911]

RC14001
ISO 9001
Audit is process wise, as per audit agenda MSDS process, Hazard communication

 

[Jen Kirley]

Do I correctly understand that you produce chemicals but are not supplying Safety Data Sheets to customers who purchase your chemicals?

 

[Moaaz0911]

We are producing chemicals and providing MSDS to customers but it is not updated as per GHS; it is in old format

 

[Jen Kirley]

You don't say what country you are in, or to whom you sell your chemicals or where. I am guessing you are aware of the United Nations
Globally Harmonized System of Classification and Labelling of Chemicals standard. Why are you not producing SDS in the updated format?

 

[Jen Kirley]

Please be aware that there are resources to assist in writing SDS in conformance with U.N. GHS structure.

 

[Moaaz0911]

We are located in Saudi Arabia,

Our products going to many countries as well as locally..(Africa Arabian countries...)
For Europe we generated SDS as per reach for that material only..

I just joined this organisation and I feel this in correct practice..