|FAQ - Regulatory Processes - Archived Through 2012
How long must an office keep the MSDS materials (in years), even if these products are no longer used?
OSAP is not in a position to provide legal advice and can only offer general information. You should consult with the college's legal counsel for all applicable laws/regulations in your state.
In addition, should your state operate a State OSHA Plan, you should contact the State OSHA office for technical assistance and interpretations of the Hazard Communication Standard.
A list of State OSHA Plans may be viewed at: http://www.osha.gov/index.html
As far as we can determine, the Hazard Communication Standard 29 CFR 1910.1200 does not specifically address the length of time one should maintain MSDSs for products no longer in use. (1)
Because potential harmful effects of exposure to hazardous chemicals (e.g. respiratory disorders, cancer, etc.) may not be apparent for years, the authors of Practical Infection Control In Dentistry state that MSDSs should never be discarded, even if the product or chemical is no longer used. When a product or chemical is no longer used in the workplace, the MSDS should be moved to an inactive section of the file but maintained as long as the office is in business. (2)
1) Hazard Communication Standard 29 CFR 1910.1200
2) Practical Infection Control In Dentistry, 2nd. Edition. By Cottone, Terezhalmy, and Molinari.
Williams & Wilkins Publishers. Copyright 1996