What to do about very old MSDS Sheets

Mikishots

Trusted Information Resource
#11
29CFR1910.1200 tells you that MSDS's are valid until changed by the manufacturer....regardless of age
Agreed, but unless the user makes periodic checks to see if the manufacturer has made a change, the user won't know. The manufacturer doesn't know who's using the product.
 
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Scott Catron

True Artisan
Super Moderator
#12
Agreed, but unless the user makes periodic checks to see if the manufacturer has made a change, the user won't know. The manufacturer doesn't know who's using the product.
According to 1910.1200(g)(6)(i):
"Chemical manufacturers or importers shall ensure that distributors and employers are provided an appropriate safety data sheet with their initial shipment, and with the first shipment after a safety data sheet is updated"

So if the user is getting regular shipments, they should be getting updated MSDS.
 

Jen Kirley

Quality and Auditing Expert
Staff member
Admin
#13
According to 1910.1200(g)(6)(i):
"Chemical manufacturers or importers shall ensure that distributors and employers are provided an appropriate safety data sheet with their initial shipment, and with the first shipment after a safety data sheet is updated"

So if the user is getting regular shipments, they should be getting updated MSDS.
I agree with the should but in my experience I couldn't rely on getting an MSDS with every shipment. I am not a lawyer, but as far as I understand it responsibilities for Right to Know fall on the employer. In respect to my work in chemical management that meant when a chemical supplier fails to even attach a proper label on the container, I was then responsible to see that the Right to Know information was still available to employees. Even if that was incorrect I believed that taking this effort would help protect my employer (and me) from liability, for specifically this, in event of legal action. This meant I periodically researched the MSDSs to make sure I was current with what was recently received.
:2cents:
 
E

escapedgoat

#14
When I was responsible for MSDSs I had a register which showed two dates (among other information such as relevant location etc). One date was the date of the MSDS, which could be months old or years old. The other date was the date which it was last checked. The requirement was that they were checked on a yearly basis, so any date longer than a year was a non-conformance.

The important date wasn't the date on the MSDS, but rather that it was demonstrated that a check had been made to ensure that there wasn't a more current revision out there.
I was responsible for just over 200 MSDSs so they were on a triggered system where a number where reviewed on a 2 monthly basis so that it was manageable.
 

Mikishots

Trusted Information Resource
#15
According to 1910.1200(g)(6)(i):
"Chemical manufacturers or importers shall ensure that distributors and employers are provided an appropriate safety data sheet with their initial shipment, and with the first shipment after a safety data sheet is updated"

So if the user is getting regular shipments, they should be getting updated MSDS.
And if they're not?
 
K

kgott

#16
Re: MSDS

By what I have been told, all MSDS's will need to be re-written to the new standard format by the end of 2013.
.
One can only live in hope MSDS preperation will centered on the end user (the worker on the shop floor using the stuff) and written in language the end user can understand and relate to, eg

5 red dots out of 7 means its bad stuff for your skin
2 red dots out of 7 means its not too bad on your lungs
7 red dots out of 7 means its all round bad stuff and you gotta use the full box and dice of PPE.
 
K

kgott

#17
I have been putting together an MSDS folder but have found that many of the data sheets available are sometimes 10-12 years old. My question is how long is an MSDS good for? Is there a required revision period? I have requested updated ones from suppliers but am wondering what the standard is on length of use. Seems that there should be a revision every so often just to ensure they are being kept up to date.
File them in the round cabinet, they are out of date.
 

TPMB4

Quite Involved in Discussions
#18
I would have thought an MSDS is one of those things worth archiving for long periods. I mean with some H&S records I believe storage times are up to 25 years. Although 10 or 12 year old MSDS's are probably out of date I believe it is no harm, indeed potentially a benefit, to archive them preferably electronically. Keep the newest one handy but older versions stored for any future reference. Might have need to see what the changes to the MSDS has been over the years.

GHS is relatively new. IIRC there has been a swtich from CHiP regulations in UK/EU to CLP and REACH. The GHS is probably just these two newer regulations put in a Worldwide language if you like (for US agreement no doubt;)).

I understand 2015 is the year for implementation of the relevant regulations / legislations in the UK (CLP and REACH). Reckon the GHS is similar now.
 

Kimmy

Involved In Discussions
#19
We keep MSDS's for 30 years AFTER we stop using the product(s) because of some form of employee exposure record must be kept for 30 years. We choose to just store the MSDS's, including those that are removed due to updates. See the 29 CFR sections below.

OSHA states at 29 CFR 1910.1200(g)(8) that the employer must ensure that the applicable MSDSs are readily accessible to employees during each work shift when the employees are in their work area(s). Thus an MSDS for a chemical must be retained for as long as that chemical is in use.

Under 29 CFR 1910.1020 (c)(5)(iii), the MSDS is considered a form of an employee exposure record. 29 CFR 1910.1020(d)(1)(ii) indicates that employee exposure records must be preserved and maintained for at least 30 years. Therefore, MSDSs must be maintained for this period of time, unless an alternate form of this information is maintained. According to 29 CFR 1910.1020(d)(1)(ii)(B) MSDSs "need not be retained for any specified period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least 30 years." Although this alternate form of keeping exposure records is an option, many organizations choose to maintain MSDSs for at 30 years so that they can preserve not only the required exposure information, but all of the information on the MSDS.
 
K

kgott

#20
I have been putting together an MSDS folder but have found that many of the data sheets available are sometimes 10-12 years old. My question is how long is an MSDS good for? Is there a required revision period? I have requested updated ones from suppliers but am wondering what the standard is on length of use. Seems that there should be a revision every so often just to ensure they are being kept up to date.
5 years thereafter bin them unless your still using the exact same substance and the new MSDS is different from the old one in all respects then keep it.
 
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