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FAQ - Regulatory Processes - 2016
FAQ - Regulatory Processes - 2016

 

 

I was wondering if you could assist me with  the updated MSDS/SDS forms.

Have all MFRS updated their forms? How can I or a dental office tell if it's the newest form with the latest information

Does a customer need to print them out in color?

How far back must a customer go back if they've ordered a product?

General information about the Hazard Communication Standard can be found on the US Department of Labor – Occupational Safety and Health Administration (OSHA) website at this link: 1
https://www.osha.gov/dsg/hazcom/index.html     

General information about the Safety Data Sheet (SDS) [formerly known as the MSDS] can be found at this link: 2
https://www.osha.gov/Publications/OSHA3514.pdf 

From the employer perspective, OSHA established a timeline for the new Hazard Communication Standard that requires employers to train employees on the new label elements and SDS format by December 1, 2013. 3

The current Hazard Communication Directive CPL 02-02-079 effective July 9, 2015  pertaining to Inspection Procedures for the Hazard Communication Standard (HCS 2012) states as follows:

·        Employers must maintain the most recent received version of the SDS (or MSDS). When an SDS is received, it must replace the MSDS for the corresponding hazardous chemical

·        Different manufacturers, importers and distributors may issue SDSs at different times. An employer that is maintaining an MSDS for a product not recently received, even after June 1, 2015, would be considered to be compliant with HCS 2012, unless the manufacturer, importer or distributor has provided an SDS and the employer did not maintain the new SDS. 4

Additional information found on the OSHA website states as follows:

Question: I'm an employer, and have not received updated SDSs or labels for some of the hazardous chemicals I use in my business. Will OSHA issue a citation to me?

Answer: No. Once you receive HCS 2012-compliant SDSs, you must maintain them. 29 CFR 1910.1200(g)(8). Once you receive HCS 2012-compliant labels, you may either maintain them on the chemical containers or follow the workplace labeling requirements contained in 1910.1200(f)(6)-(10). 5

And,

Employer Responsibilities Employers must ensure that the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers as long as the employees have immediate access to the information without leaving their work area when needed and a back-up is available for rapid access to the SDS in the case of a power outage or other emergency. Furthermore, employers may want to designate a person(s) responsible for obtaining and maintaining the SDSs. If the employer does not have an SDS, the employer or designated person(s) should contact the manufacturer to obtain one. 6

The emphasis is upon providing ready access to SDS’s for employees, which can be done via hard copies in binders or by electronic means.

From the product manufacturer’s and distributor’s perspective, Inspection Procedures for the Hazard Communication Standard (HCS 2012) provides detailed information regarding manufacturer and distributor requirements for the SDS. It can be accessed at this link: 4
https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-079.pdf    

It says in part:

Chemical manufacturers and importers must develop safety data sheets in accordance with the HCS 2012 by June 1, 2015. 4

And,

Employers are required to maintain SDSs (or MSDSs) for each hazardous chemical they use. The HCS does not specify how the SDS (or MSDS) is to be maintained (e.g., paper, electronic), as long as employees have immediate access to the SDS (or MSDS) in their work area. (Note: Older versions of SDSs (or MSDSs) may still need to be maintained as an employee exposure record under OSHA’s Access to employee exposure and medical records standard, 29 CFR 1910.1020). 4

This link to an OSHA Fact Sheet provides information pertaining to Hazard Communication requirements for manufacturers: 3
https://www.osha.gov/dsg/hazcom/HCSFactsheet.html 

This document says that Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. 3

Resources

1)     US Department of Labor – Occupational Safety and Health Administration. Hazard Communication. https://www.osha.gov/dsg/hazcom/index.html   Accessed on April 18, 2016.

2)     US Department of Labor – Occupational Safety and Health Administration. OSHA – Brief - Hazard Communication Standard: Safety Data Sheets.  https://www.osha.gov/Publications/OSHA3514.pdf   Accessed on April 18, 2016. 

3)     US Department of Labor – Occupational Safety and Health Administration. OSHA Fact Sheet – Hazard Communication Standard Final Rule. https://www.osha.gov/dsg/hazcom/HCSFactsheet.html   Accessed on April 18, 2016.

4)     US Department of Labor – Occupational Safety and Health Administration. Hazard Communication Directive CPL 02-02-079. https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-079.pdf   Accessed on April 18, 2016.

5)     US Department of Labor – Occupational Safety and Health Administration. Memo - Enforcement Guidance for the Hazard Communication Standard's (HCS) June 1, 2015 Effective Date. https://www.osha.gov/dep/enforcement/hazcom_enforcement-memo.html   Accessed April 18, 2016.

6)     US Department of Labor – Occupational Safety and Health Administration. OSHA Brief – Hazard Communication Standard: Safety Data Sheets. https://www.osha.gov/Publications/OSHA3514.pdf   Accessed on April 18, 2016.

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