DCHAS-L Archives Feb 23 2011 - Re: MSDS Retention

I am still researching the topic about MSDS retention I submitted earlier and found this OSHA Interpretation letter from Oct. 1987, which states:

This is in response to your letter of September 1, requesting an interpretation of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard.

Specifically, your letter addresses the problem of what to do with superseded material safety data sheets. The Hazard Communication Standard requires that employers maintain copies of material safety data sheets for each hazardous chemical used in the workplace. Employers may discard a material safety data sheet for a mixture, if the new data sheet includes the same hazardous chemicals as the original formulation. If the formulation is different then the employer must maintain both data sheets for at least 30 years. OSHA standard, 29 CFR 1910.1020, Access to employee Exposure and Medical Records defines "employee exposure records" to include material safety data sheets. The standard requires all employee exposure records to be maintained for at least 30 years.

An alternative to keeping both data sheets, however, is provided for in 29 CFR 1910.1020. Under paragraph (d)(1)(ii)(B) of this standard employers may discard material safety data sheets if some record identifying the substances used, where it was used and when it was used is retained for at least 30 years. Therefore, an employer may discard the original data sheet and retain only the new data sheet if a record on the original formulation is maintained.

So…. It sounds like I can discard old versions of MSDSs if we have “some record identifying the substances used, where it was used and when it was used” and retain THAT for at least 30 years. I will have to determine whether I think we have that or not, I believe we do now that we are a GMP operation, but perhaps not before our GMP days.

I would still be interested in knowing others take on this and how they handle it.

Thanks,

Pat

From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Peifer, Patricia
Sent: Wednesday, February 23, 2011 9:06 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] MSDS Retention

A debate has come up within our organization concerning the retention of MSDSs. I have been saving old copies of MSDSs for which new revisions have been issued. My understanding is that this would be proof that we did have the MSDS on file if an employee claimed twenty years later that they were exposed to a chemical and said we did not provide them with adequate information. I planned on keeping them for thirty years.

Others in my organization feel I may be wasting my time. They feel I should be throwing out older versions and only retaining the latest copy particularly if the revisions were not significant. They do agree however, that I should be keeping old MSDSs for chemicals for which we discontinue use.

Any thoughts? Thank you, everyone.

Pat Peifer

Health Safety and Training Team Leader

West Pharmaceutical Services

Find West on Twitter and LinkedIn.

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