Tuesday, April 21, 2009

Updating MSDS Sheets

Question:
Some of the MSDSs maintained by our system include a statement that the information contained on the MSDS is "valid on the date of printing only." If a MSDS is printed containing the aforementioned quoted statement on one day, and then one wants to refer to the same MSDS on a later date, would the document be deemed valid on any other date? Would an MSDS with such a statement be considered to be in compliance with OSHA regulations.

Answer:
OSHA's hazard communication standard (HCS), 29 CFR 1910.1200(g)(2)(xi) states that MSDSs shall contain ". . .[t]he date of preparation of the material safety data sheet or the last change to it . . . " A material safety data sheet is intended to be a reference document that reflects the most accurate and current information about a specific hazardous chemical (product) that is available at the time that the MSDS is developed. It is imperative that an MSDS is a correct reflection of current scientific information related to the hazardous chemical or product, again, as of the date that the MSDS is prepared. Failure to include a preparation date on the document would be a violation of 29 CFR 1910.1200(g)(2)(xi). It is the chemical manufacturer's (or the responsible party's) obligation to ensure that the information contained on an MSDS is accurate and meets the requirements of the HCS. The document would be deemed in violation of the HCS if the dates required by the standard were not included on the document. As you may know, the MSDS must accompany the initial shipment of a hazardous chemical to the downstream user. MSDSs must be updated whenever the required information on the data sheet changes and the updated data sheet must then be sent with the next shipment of the chemical to the downstream user. MSDSs are therefore tied to the initial shipment of the chemical, and the information on the data sheet would be considered current for that particular shipment of the chemical, and remains valid until such time that the information gets updated. Thus, a statement that the information is "valid on the date of printing only" is inconsistent with the requirements of the HCS. The MSDS is valid until the information is superseded, and without the date of preparation or last change, it is difficult for the user to know whether it is a correct reflection of current scientific information. This statement also inappropriately attempts to place the duty of learning about updates on the user; the HCS places the duty of providing updated MSDSs on manufacturers, importers, and distributors.

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