MSDS Sheets in ISO-14001 2004 - Should MSDS sheets be "controlled documents"?

[Randy]

Being kind of new at this and not having much experience to fall back on I'll try to wade into the subject at hand

Bottom line (as far as the EMS is concerned, remeber there may be other issues)

If MSDS's are identified as "system" required documentation they have to be controlled, if not, they don't.

If you have Title V permits and MSDS's are required in performing mass balance calculations (normally it's going to be CPDS's that are required, but there are always exceptions) then they are system documents requiring control.

It's up to each organization to "define" its own documentation requirements beyond the minimum specified in 4.4.4 and throughout the standard when it references "records" and other stuff.

Now if an organization is doing something real crazy, like using MSDS's to serve as the "characterization" of hazardous wastes, they they also become system documents requiring whatever controls have been established.

The only time an MSDS is not an "external" document is when the orgaization is the "originating source" or "writer" of it because it produces the material requiring the generation of the MSDS I/A/W US OSHA statutes.

The MSDS is primarily an occupational safety related document that has been adopted for use in other areas like environmental compliance and consumer product safety under certain specified conditions by the regulatory agency involved.

Then again, what would I know about it?

 

[James Gutherson]

Again, forgetting all the EMS, OHSMS stuff, ask what do I use the document for? Is it important that I have the most up-to-date version available where I need it? If so it sounds like there should be some system to make sure that happens.

 

[Randy]

I explained what the document is for in the last sentence, but I'll expand it a bit.

Basically US OSHA requires employers who have employees that use what are identified as "hazardous materials" (as defined by OSHA) in the workplace to maintain Material Safety Data Sheets for each material. MSDS's contain safety realated and other information about the material. Manufacturers who make "hazardous materials" are required to generate MSDS's that provide basic information required by US OSHA.

The term "hazardous material" can be greatly misunderstood and abused because even something like distilled water used in the workplace by an employee during the course of his/her work can require an MSDS. Sounds like overkill, but it's a crazy world.

If I misunderstood what you meant, I'll blame it on the Bud I just had because the hotel doesn't have Foster's.

 

[tarheels4 - 2007]

Again, forgetting all the EMS, OHSMS stuff, ask what do I use the document for? Is it important that I have the most up-to-date version available where I need it? If so it sounds like there should be some system to make sure that happens.

I reckon you do what you have to, to comply with the laws in your COUNTry. That is what you have to comply with. Sorry, I have had some buds too.

PS. I wish you were from France

 

[James Gutherson]

PS. I wish you were from France

What? I don't get the French reference.

Sorry if you misunderstood me, I was trying to explain my view in answering the question, not asking another. (I know what a MSDS is, and we have the same laws in Australia).
My take on the question was 'Do I need to control X document in my Z Management Sysytem?'

My answer to this is the same regardless of what type of management system is being considered. "Well, what do you use it for, and do you need to use the most up to date (or a specific) version?'

This to me is the essence of document control (in all MS standards), ensuring that the right document is available and used when required.

Now for a MSDS, most (if not all) countries have laws requiring them to be issued, and they are to used to develop safe procedures (for people and the environment) to handle these materials. They are typically addressed during the devlopment of procedure and possibly also in the performance of the actual procedure. My take on this would be "yes it is necessary that I have current versions of MSDS' (not discounting any specific legal requirement or Standard requirement), so I must develop some way of ensuring this".

I guess I was just trying to provide a more generic way of looking at what documents need to be controlled.

Sorry if the last part was not too clear I need to get some lunch, no Bud's for me as it's only midday here, but it is Friday

 

[tarheels4 - 2007]

I guess I was just trying to provide a more generic way of looking at what documents need to be controlled.

Sorry if the last part was not too clear I need to get some lunch, no Bud's for me as it's only midday here, but it is Friday

James, my understanding is that if, in regards to ISO 14001 and if an organization decides that chemical use is a significant aspect, then maybe the MSDS process should be a part of the EMS document control system. Most companies that I am familiar with consider MSDS sheets as EMS records and there is a legal OSHA requirement that a company keep them 30 years after use of the chemical.

My experience has been is that most companies consider the MSDS sheet a record of chemicals used over the years and list the MSDS as a 30 year retention after they have been discontinued but not an EMS document.

The process of control of MSDS sheets as a document, in my experience has not been an EMS or QMS function

But, it could be.

 

[James Gutherson]

My experience has been is that most companies consider the MSDS sheet a record of chemicals used over the years and list the MSDS as a 30 year retention after they have been discontinued but not an EMS document.

The process of control of MSDS sheets as a document, in my experience has not been an EMS or QMS function

But, it could be.

Agreed, that's what I was trying to say. With any question of 'should this document be a controlled document?' the company needs to look at how they use it.

 

[db]

James, my understanding is that if, in regards to ISO 14001 and if an organization decides that chemical use is a significant aspect, then maybe the MSDS process should be a part of the EMS document control system.

Agreed! That is my take as well, but I wanted to see what the consensus was of the group. I also wanted to see if anyone would say that MSDS “had” to be part of the EMS. If they thought that, I was interested in their reasoning.

 

[Randy Stewart]

Exactly! Nothing tells me that I have to have them in my Ctrl Doc system. Under 4.4.5 it calls for controlling documents required by the standard. MSDS is not called out specifically as a required document.

 

[SteelMaiden]

I was glad to find this thread. I was recently (coughs into hand ) promoted to ISO coordinator, instead of Quality coordinator. Now I find myself in the midst of an attempt to implement 14001. I had previously told the manager of environmental dept. my thoughts on what he needed to perform implementation, giving him all kinds of advise/examples and offering my help. He rejected every suggestion I gave him so I just bowed out and let him hang himself. Now my boss, who is his boss too, has demanded that I "take control of the implementation and "put my fingerprints all over it" " Oh, boy.

Anyway, we had just had the MSDS talk and I told them that we should continue to put safety and health in the role of document maintenance, but aknowledge the fact that MSDS sheets are also an "external document" that is needed as a resource for environmental. Glad to see that even though I am not an environmental guru, I got one right! LOL