Subject: 6 Re: [DCHAS-L] MSDS Retention
From: "Alnajjar, Mikhail S" <ms.alnajjar**At_Symbol_Here**pnl.gov>
Date: February 24, 2011 11:46:55 AM
EST
Subject: RE: [DCHAS-L] MSDS
Retention
Good
point. Somehow the 30 years makes us feel safe and protected!!! My
other two cents. But, it is required that we have to follow the
codes.
===
Date: February 24, 2011 1:18:37 PM
EST
Subject: Re: [DCHAS-L] MSDS
Retention
The
intent of the OHSA regulation is to keep track of worker exposures. The
MSDS is considered to be an exposure record. Therefore you must retain
it for employment plus 30 years.
Bill
Watt
Wayne State
U.
===
From: DCHAS-L Discussion List
[mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Mary Ellen Abel
Sent: Wednesday, February 23, 2011 10:05 AM
Subject: Re: [DCHAS-L] MSDS Retention
It is my
understanding that the '30 years' refers to the date of the last
potential exposure, not the data that the MSDS was received. So
that 30 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 products 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
===
Date: February 24, 2011 12:56:46 PM
EST
Subject: Re: [DCHAS-L] MSDS
Retention
>I agree - I see a lot of =93kits=94 in biology
and frankly the MSDS is useless!
>It is
practically impossible to know what is in these products and how to
dispose of the waste.
>I am
keeping the MSDS though!!
Good. You've done due dilligance and it is the
manufacturer that becomes the Defendant if something goes
wrong. Monona
===
Date: February 24, 2011
2:52:25 PM EST
Subject: Re: [DCHAS-L] MSDS
Retention
All of
your suggestions as to WHY retention of MSDSs are valid and useful (may
be needed to justify health claims; regulatory requirement, etc). BUT -
as the MSDS point person for our large university who is responsible for
19,000++++ MSDSs, I can tell you that it is a difficult and daunting
task. Where do I store them? My "archive space" was just demolished to
make room for more classrooms. Digitize/scan them? Who is going to scan
that many pieces of paper? Who is going to pay for that? What about in
10 years when that technology is no longer valid (I have a few zip discs
of MSDSs I can no longer open!) Keep a running inventory of what product
is being used in each lab by person? Come visit & tell me it can be
done!
I've got
BOXES of MSDSs stored - yes I've met the regulatory requirement.
Kim
Auletta
Lab Safety
Specialist
EH&S
Z=6200
Stony Brook
University
631-632-3032
FAX:
631-632-9683
===
Date: February 24, 2011 12:53:40 PM
EST
Subject: Re: [DCHAS-L] MSDS
Retention
Good
point Edward. When we do litigation, we try to get MSDSs going
back as far as we can get them to see what the different claims have
been over time. And those get compared with the studies that are
available to see what the manufacturer should have known at any given
time.
We even get whole sets of product catalogs to see what
the adverstizing and product literature claimed at various
times.
Monona
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