MSDS Sheets for Products - How much is too much - Or is there ever too much?

R

rlsavard

#1
I recently self-assigned myself to better organize our MSDS binder, and I was shocked at some of the MSD Sheets that we have. One that really baffles my mind is for a denim apron one of our guys uses. Really? An MSDS for denim? Although it's not as lengthy as, say, cleaning solution, it still just makes me crazy that one exists. The major note on this sheet is that it's combustible--surprise!

Well, that got me into some research here on the cove. I've seen people say we need an MSDS for every hazardous material that our employees could be exposed to. So of course I went through the building, compiled a list of all "hazardous" materials and then updated our MSDS binder to include the newly acquired MSD Sheets for items such as ink cartridges and hand soap.

When I shared this with some of my coworkers people said that the other shops they worked out never went this in-depth (although that doesn't mean they were doing it correctly.)

I'm just wondering if there is any way I can stop having to get MSD Sheets for things like hand soap, bathroom cleaner, or ink cartridges. After reading through some of the old posts I even found MSD Sheets for white vinegar and table salt because we used those two "hazardous" items to shine up some parts.

Is this all necessary or am I going over the top? I realize I've done most of the hard work by compiling the list and by tracking down the MSD Sheets, but I would still like to know if it is all necessary or not.

Thanks for your time and for your patience! Any insight is greatly appreciated.
 
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somashekar

Staff member
Super Moderator
#2
Re: MSDS - how much is too much--or is there ever too much??

Well, it is just a good thing that they are available. How much of MSDS you use depends upon how much impact it has on you OR how much you can visualize.
Look at things like what have hapened ...
Tincher iodine has been taken and consumed mistaking it as a cough suppressant.
Dettol has been used in eye injury case.
Battery distilled water consumed when thirsty.
Have you seen the MSDS of Dettol ? Well, there is a very detailed one. I have seen MSDS also for a Jersy cloth.
MSDS is the information sheet that tells you a whole lot about what could happen in all possible situations.
Remember that OHSAS planning wants you to consider human behaviour, capabilities and other human factors.
Well petrol looks like Whisky >>> ;)
 

Randy

Super Moderator
#3
Re: MSDS - how much is too much--or is there ever too much??

Most organizations and "professionals" go way, way overboard with MSDS's. All you have to do is go by 29CFR 1910.1200 and the OSHA interpretation documents.

Pay particular attention to the phrase "consumer comodity" in the regulation because it can really reduce the number of MSDS's you actually have to keep.

An MSDS for denim in an apron though is about as lame as it gets unless you manufacture the denim and coloring.

www.osha.gov

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099

http://www.osha.gov/pls/oshaweb/owa...level=3&p_keyvalue=1910.1200&p_status=CURRENT
 
R

rlsavard

#4
Re: MSDS - how much is too much--or is there ever too much??

Employers shall maintain copies of any material safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals, shall obtain a material safety data sheet as soon as possible for sealed containers of hazardous chemicals received without a material safety data sheet if an employee requests the material safety data sheet, and shall ensure that the material safety data sheets are readily accessible during each work shift to employees when they are in their work area(s)
Wow! That makes things simple -- only keep what you receive, and only obtain when requested by an employee? Too simple. That is a very big sigh of relief, although like I said before I already got most of them!

I also read, however, that suppliers are supposed to send a MSDS when new customers order something, then only send the MSDS if an update has occurred. Obviously if this was the case then the quote above would work flawlessly. If, however, I order something (carbide tooling, say) and don't receive a MSDS from the supplier, is it my responsibility to track them down and ask them for it? Or should I only worry about it if an employee asks about it?
 

ScottK

Not out of the crisis
Staff member
Super Moderator
#5
Re: MSDS - how much is too much--or is there ever too much??

I'm glad you're making some sense of it.

My company keeps a tremendous database of MSDS's in corporate HQ.
Since I'm not responsible for maintaining it, I don't give it much thought but I can tell you that comes in handy for RoHS and REACH research.

What I was recently able to do (with help from a corporate guru) was run a search on all REACH SVHC's and candidates and see that nothing on the list will be applied to the customers' priduct ... that makes our REACH reporting to customers A LOT easier.

how this affects what you are going through.... I had to have an MSDS for for pressure sensitive label stock... something most people might not otherwise think about.

Lesson - if you're exporting to the EU, having "crazy" MSDS's may be a help.
 
G

George Weiss

#6
Re: MSDS - how much is too much--or is there ever too much??

This is an area where there seems to be no limit to the items to include. The air in central Los Angeles could/would need a sheet. This process along with many is evolving, and supported by the thought of not wanting to under-do it. There was a good point to draw the line, when it was an item that was an identified cancer risk, or an acid, or a significant flammable material. Once we list wood for being flammable, we have reached a tipping point.
The Environment, Health and Safety policy is:
A list of hazardous materials and chemicals which are used in the course of the company's Sheet (MSDS).normal business activities must be maintained and continually updated. This list is to include all substances, which require a Material Safety Data. Reference @
http://www.ehso.com/oshaguides/hazcom.doc
HAZARDOUS MATERIAL:[FONT=Arial, Arial][FONT=Arial, Arial]
Any substance or mixture of substances having properties capable of producing adverse effects on the health or safety of a human being. Reference @
[/FONT]
[/FONT]http://www.ehso.com/msdsdefs.php
[FONT=Arial, Arial][FONT=Arial, Arial]Maybe denim is not hazardous unless used to choke someone. This is a coin flip situation.
[/FONT]
[/FONT]
 

Randy

Super Moderator
#7
As simple as it gets you only need to goby US OSHA's definition of hazardous material and it's only for those things used in the workplace.

If, however, I order something (carbide tooling, say) and don't receive a MSDS from the supplier, is it my responsibility to track them down and ask them for it?
This would be unreasonable unless there is an exposure potential that could cause injury or ill health of an employee from chemical interaction. I've survived half-a-hundred OSHA (of which quite a few were CalOSHA) inspections and some of which were based on employee complaints and they never, never, never asked for an MSDS for denim, white out or a tool. My last CalOSHA compliance officer would have told me I was stupid if I had actually had them.

Hey, I only have a degree in safety and 20+ years in the field so I can only rely on my eductaion, training and experience in answering your question.
 
R

rlsavard

#8
As simple as it gets you only need to goby US OSHA's definition of hazardous material and it's only for those things used in the workplace.

This would be unreasonable unless there is an exposure potential that could cause injury or ill health of an employee from chemical interaction. I've survived half-a-hundred OSHA (of which quite a few were CalOSHA) inspections and some of which were based on employee complaints and they never, never, never asked for an MSDS for denim, white out or a tool. My last CalOSHA compliance officer would have told me I was stupid if I had actually had them.

Hey, I only have a degree in safety and 20+ years in the field so I can only rely on my eductaion, training and experience in answering your question.
Randy, your education, training and experience are good enough in my book. I was hoping I would receive an answer like this, but was expecting the worst.

Thanks for your time, everyone. I really do appreciate it.
 

Randy

Super Moderator
#9
Hey you're welcome, just make sure to study 1910.1200 and the interpretations OSHA has from folks asking questions just like you.
 
S

samsung

#10
Is this all necessary or am I going over the top? I realize I've done most of the hard work by compiling the list and by tracking down the MSD Sheets, but I would still like to know if it is all necessary or not.
You have to keep MSDS for every chemical (my emphasis on 'chemicals' only) that's hazardous but this doesn't mean that every MSDS available or created by you relates to a hazardous chemical.

What's most important is to understand what's a Hazardous Chemical that requires, as a minimum, that an updated MSDS be available at site. You can't find this information anywhere but in the rules/ regulations pertaining to Hazardous Chemicals which not only define what's hazardous but also provide lists of different categories of Haz. Chemicals (like toxic, flammable, corrosive, reactive, explosive etc.). The chemicals not included in the list can't be hazardous ones and as such you can well scrap all the unrelated MSDS.

The legal definition of Hazardous Chemicals, in my country, is as under:

(i) any chemical which satisfies any of the criteria laid down in Part I of [Schedule 1 or] listed in Column 2 of Part II of this Schedule ;

(ii) any chemical listed in Column 2 of Schedule 2;

(iii) any chemical listed in Column 2 of Schedule 3;
You may check with the prevailing rules in your country and I'm sure the definition of Haz. Chem. shouldn't be much different from the above one.

Thanks.
 
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