With regard to the regulatory requirement, laboratories are only required to maintain SDSs which the chemical supplier sends.. Laboratories are not obligated to request a
SDS from the supplier. Of course, many labs choose on their own to request a SDS if it was not provided.
Non-laboratory workplaces are required to have a SDS for every chemical present., and must request one from the supplier if was not provided.
Below is a cut and paste from the OSHA interpretations (www.osha.gov, then "Enforcement:, then “Standard
Interpretations”).
----------------------------------------------------
Staff Industrial Hygienist
Oklahoma City, Oklahoma 73125
This is in response to your letter of November 28, 1988, and a follow-up to your telephone conversation with Mrs. Jennifer Courtney of my staff, in which you requested an
interpretation of the Hazard Communication Standard (HCS), 29 CFR 1910.1200, as it relates to laboratories and our requirements with respect to material safety data sheets (MSDS). Please accept my apology for the delay in this written response.
The HCS addresses laboratories in a more limited fashion than it does for other types of establishments. An employer is only required to maintain those MSDS which the supplier
sends. There is no affirmative obligation for a laboratory to request or otherwise procure data sheets.
We appreciate the opportunity to address your concerns. Please do not hesitate to contact us again if you have further questions.
Patricia K. Clark, Acting Director
Directorate of Compliance Programs
--------------------------------
Assistant Director, Laboratory Safety
Environmental Health and Safety Dept., MS 328
University of Nevada, Reno 89557
Office Phone: 775-327-5196
OSHA says: Employers are required to have SDSs for all hazardous chemicals that they use
If you do not receive an SDS automatically, you must request one as soon as possible. If you cannot show a good faith effort to receive the SDS, you can be cited for not having
the SDS for a hazardous chemical
If any are missing, contact your supplier and request one. It is a good idea to document these requests, either by keeping a copy of a letter or e-mail, or a note regarding
telephone conversations
Do not allow workers to use any hazardous chemicals for which you have not received an SDS. The SDS provides information you need to ensure that proper protective measures
are implemented prior to worker exposure.
If you receive an SDS that is obviously inadequate, with, for example, blank spaces, you must request an appropriately completed one.
If your request for an SDS or for a corrected SDS does not produce the information needed, you should contact your local OSHA area office for assistance in obtaining the SDS.
Some suppliers provide SDSs for products that are not hazardous. These SDSs do not have to be maintained.
OSHA Says: In order to ensure that you have a current SDS for each chemical in the plant as required, and that worker access is provided, OSHA's CSHOs will be looking for the
following items in your program:
Designation of person(s) responsible for obtaining and maintaining the SDSs;
How such sheets are maintained in the workplace (e.g., in notebooks in the work area(s) or electronically), and how workers obtain access to them when they are in their work
area during the work shift;
Procedures to follow when the SDS is not received at the time of the first shipment;
An SDS for each hazardous chemical in the workplace, and training of workers that includes review of SDS format and use.
-----Original Message-----
Sent: Tuesday, February 03, 2015 1:25 PM
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
The lab standard requires that: "1910.1450(h)(1)(ii) Employers shall maintain any safety data sheets that are received with incoming shipments of hazardous chemicals, and ensure
that they are readily accessible to laboratory employees"
So if the vendor or manufacturer did not supply an SDS it doesn=B9t appear you must have one. I am not sure OSHA can require you to produce an SDS if you say that it was not
supplied with the chemical.
Environmental Health and Radiation Safety University of Pennsylvania
website:www.ehrs.upenn.edu
-----Original Message-----
Date: Friday, January 30, 2015 at 10:30 AM
Subject: [DCHAS-L] Are SDS for existing chemicals required?
>Do I need GHS compliant Safety Data Sheets for existing chemicals?
>Do I still keep the original MSDS as well?
>Do they have to be from the original manufacturer?
>What if the manufacturer no longer exist?
>Thanks in advance for your help,
>Instrumentation Specialist
>Laboratory Development Assistant
>Campus Chemical Compliance Director
