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Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
Date: Friday, January 30, 2015 12:48:42 PM
Author: Monona Rossol <actsnyc**At_Symbol_Here**cs.com> 		Next by Date:
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
Date: Fri, 30 Jan 2015 18:22:39 +0000
Author: "Bradley, Shelly"

(Note: This post is 10 years old and may contain outdated information.)

From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?
Date: Fri, 30 Jan 2015 13:15:27 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 14b3c0e0920-7d79-21dd**At_Symbol_Here**webprd-m17.mail.aol.com
In-Reply-To <14b3bf589e6-22de-1ebf**At_Symbol_Here**webprd-a07.mail.aol.com>


Oops, I forgot the last question: "What if the manufacturer no longer exist[s]?"
 
Technically, the stuff is waste since there is no one responsible for it. But the school can take the responsibility and produce a SDS with their own name/address at the top.
 
This is truly an interesting legal problem because it also enables employees to sue their employer rather than accept workers' comp. If they claim injury or illness from the use of this orphaned product, they can file suit under Product Liability since the school is now the "manufacturer of record." I've never seen a lawsuit like this but I have seen it used as a route to a settlement with an employee.
 
Seems easier to dispose of the stuff with no existing manufacturers.
 
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062
actsnyc**At_Symbol_Here**cs.com   www.artscraftstheatersafety.org

 
 
 
-----Original Message-----
From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Fri, Jan 30, 2015 12:48 pm
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required?

Perfect.  Except that vendors do not have to supply SDSs legally.  Most do, however, as a customer service.  The legal onus is on the manufacturer.
 
 
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062

 
 
 
-----Original Message-----
From: Zydnia Madera <zmadera**At_Symbol_Here**ETBROWNE.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Sent: Fri, Jan 30, 2015 12:30 pm
Subject: Re: [DCHAS-L] Are SDS for existing chemicals required? 

See below.

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Bradley, Shelly
Sent: Friday, January 30, 2015 10:30 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] Are SDS for existing chemicals required?

Do I need GHS compliant Safety Data Sheets for existing chemicals?                 Yes, by June 1,2015
Do I still keep the original MSDS as well?                                                  Yes, depending the states the law says for 30yrs plus the time of the employment of your employees
Do they have to be from the original manufacturer?            They should be from your vendor/manufacturer.
What if the manufacturer  no longer exist? 

Thanks in advance for your help,
Shelly

Shelly Bradley
NRCC-CHO
Authorized OSHA Trainer
Instrumentation Specialist
Laboratory Development Assistant
Campus Chemical Compliance Director
Department of Chemistry
Hendrix College
Conway, AR 72032
Ph:	(501) 450-3812
Fax:	(501) 450-3829
bradley**At_Symbol_Here**hendrix.edu

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