Aha - now it makes sense. I forge
t about those guys sometimes.
Sorry.
Actually we are not an OSHA regulated
facility, we are an MSHA regulated facility, Mine Safety Health Administrat
ion. Similar rules, not identical, but a much different focus.
Mary Ellen Abel
Quality Assurance & Environmental Manager
Morton Salt
P.O. Box 428
Grand River, OH 44045-0428
phone: 440-639-4279
fax: 440-639-4269
cell: 440-479-9022
"Long, Don&q
uot; <don.long**At_Symbol_Here**WGINT.COM>
Sent by: DCHAS-L Discussion List <D
CHAS-L**At_Symbol_Here**list.uvm.edu>
02/23/2011 06:21 PM
|
Please respond t
o
DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**list.uvm.edu>
|
|
|
To
|
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU |
|
cc
|
|
|
Subject
|
Re: [DCHAS-L] MSDS Retention |
|
Ohio falls under the Federal OSHA, so I'm s
ure that facility is an "OSHA regulated" facility.
As far as maintaining MSDSs, it's not that
difficult to maintain them electronically. We are supposed to be in the bus
iness of taking care of folks. I don't understand the conflict here. We are
already required to maintain medical
records of employees employed more than 1 year for "the duration of e
mployment plus 30 years". It stands to reason that the MSDSs would fol
low the same reasoning.
I know when the Feds audit us (Army, CDC, O
SHA, etc) their response is that if it's been used then we better have an M
SDS. In the Haz-Com exerpt below, it seems to make it clear that we "s
hall maintain copies of any MSDSs that are
received with incoming shipments...".
1910.1200(b)(4)(ii)
"Employers shall mai
ntain copies of any material safety data sheets that are received with inco
ming shipments of the sealed containers of hazardous chemicals, shall obtai
n a material safety data sheet as soon as possible
for sealed containers of hazardous chemicals received without a material s
afety data sheet if an employee requests the material safety data sheet, an
d shall ensure that the material safety data sheets are readily accessible
during each work shift to employees
when they are in their work area(s);"
Just some thoughts....
Don A. Long
CAIH, CEAS I
Southwest Research Institute Laboratory
Pine Bluff Chemical Agent Disposal Facility
PO Box 20130
White Hall, AR 71612
870-541-4930
From: DCHAS-L Discussion List [mail
to:DCHAS-L**At_Symbol_Here**list.uvm.edu]
On Behalf Of Mary Ellen Abel
Sent: Wednesday, February 23, 2011 10:05 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] MSDS Retention
It is my understanding that the '30 years' refers to the date of the last p
otential exposure, not the data that the MSDS was received. So that 3
0 years might actually be 45 years, if that individual used it for a period
beyond its first use. Although I am
not in an OSHA regulated facility, we have been screening MSDSs for produc
ts used in our underground mine long before Haz Com was ever developed.
Mary Ellen Abel
Quality Assurance & Environmental Manager
Morton Salt
P.O. Box 428
Grand River, OH 44045-0428
phone: 440-639-4279
fax: 440-639-4269
cell: 440-479-9022
"Peifer, Pat
ricia" <Patricia.Peifer**At_Symbol_Here**WESTPHARMA.COM>
Sent by: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**list.uvm.edu>
02/23/2011 09:17 AM
|
Please respond t
o
DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**list.uvm.edu>
|
|
|
To
|
DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
|
|
cc
|
|
|
Subject
|
[DCHAS-L] MSDS Retention
|
|
A debate has come up within our organization concerning the retention of MS
DSs. I have been saving old copies of MSDSs for which new revisions h
ave been issued. My understanding is that this would be proof that w
e did have the MSDS on file if an employee
claimed twenty years later that they were exposed to a chemical and said w
e did not provide them with adequate information. I planned on keepi
ng 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 pa
rticularly if the revisions were not significant. They do agree howe
ver, 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.
The contents of this message are confidential and may be p
rivileged. If you have received this message in error, please permanently d
elete it, along with any files that may be attached to this message, withou
t reading, printing, copying, forwarding
or otherwise distributing it. Please notify the sender of the error immedi
ately so that we can prevent it from happening again.
This e-mail and any attachments contain URS
Corporation confidential information that may be proprietary or privileged
. If you receive this message in error or are not the intended recipient, y
ou should not retain, distribute, disclose
or use any of this information and you should destroy the e-mail and any a
ttachments or copies.
This e-mail and any attachments contain URS Corporatio
n confidential information that may
be proprietary or privileged. If you receive this message in error or are
not the intended recipient, you should not retain, distribute, disclose or
use any of this information and you should destroy the e-mail and any attac
hments or copies.
Previous post | Top of Page | Next post
