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Previous by Date: Subject: Re: Laboratory Risk Statement Date: Thu, 12 Feb 2004 17:18:52 -0500 Author: Ninette Burns |
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>I am not affiliated with a university; I work for a manufacturer of crop
>protection chemicals. We implement the OSHA Lab Standard found in the
>Code of Federal Regulations Volume 29 Part 1910 (available online) which
>specifies that we must have readily accessible all MSDSs for chemicals that
>are on site. "Ready access" is a key concept - they can't be limited to a
>locked office. My opinion, based on the OSHA interpretation, is that
>providing information to students on how to obtain MSDSs is not enough,
>although it is certainly a good thing to include.
Note also that employees must have ready access to the MSDS's in
their entirety, not "MSDS information". There's an important
difference between having safety facts about a chemical and having a
complete set of data that includes manufacturer emergency contact
information.
While students in many cases may not fall under the purview of 29 CFR
1910.1200, OSHA requires that any employee potentially exposed to
hazardous chemicals in the workplace be able to retrieve MSDS's for
those chemicals and to do so unassisted. Inspectors will quiz
employees to ascertain whether their training and knowledge of the
hazards is adequate. Holding students to the same expectation is not
unreasonable, particularly in the context of fostering a
"professional safety culture" attitude.
>I recommend that actual
>MSDSs be on hand for immediate access, such as in a file cabinet in the lab
>area or storeroom. The MSDS contains information that is helpful to know
>BEFORE it is used, and will tell the reader what to expect in case of an
>accidental exposure incident, and what to do about it. Such a simple thing
>as knowing how to read an MSDS can help dispel unwarranted fears of
>"chemicals." Reading the MSDSs prior to starting the labwork should be
>part of the lab experience in order to develop the habit.
While I concur that up-to-date hard copies of MSDS's are great to
have in the lab or workplace, note that the "ready access"
requirement does permit "paperless compliance" methods. See our MSDS
FAQ question on the topic at
http://www.ilpi.com/msds/faq/partd.html#paperless for more
information as well as official OSHA interpretations on the subject.
Regardless of the method, MSDS's are part of the written hazard
communication/training and are supposed to be read before the
chemical is used. That is why they are required to be shipped with
or before the first shipment of a chemical from a supplier.
Best regards,
Rob Toreki
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