Simply posting an SDS on the manufacturer or distributor's site does NOT satisfy the SDS distribution requirements of the HazCom Standard. They must be transmitted to their downstream users. Posting SDS's on their website is not required, either (but it should be!).

The manufacture/importer/distributor is required to supply an SDS before or with the first shipment of a chemical (or if the sheet has been updated since the last shipment). You can arrange by mutual agreement to do that electronically if you wish, but it is still typically done on paper.

29 CF1910.1200, the OSHA Hazard Communication Standard specifically handles manufacturer responsibility at paragraph (g)(6), http://www.ilpi.com/msds/osha/1910_1200.html#1910.1200(g)(6) :

(g)(6)(i) Chemical manufacturers or importers shall ensure that distributors and employers are provided an appropriate safety data sheet with their initial shipment, and with the first shipment after a safety data sheet is updated;

(g)(6)(ii) The chemical manufacturer or importer shall either provide safety data sheets with the shipped containers or send them to the distributor or employer prior to or at the time of the shipment;

(g)(6)(iii) If the safety data sheet is not provided with a shipment that has been labeled as a hazardous chemical, the distributor or employer shall obtain one from the chemical manufacturer or importer as soon as possible; and,

(g)(6)(iv) The chemical manufacturer or importer shall also provide distributors or employers with a safety data sheet upon request.

Paragraph (g)(7) is similar, but directed at distributors and for retail locations like Home Depot that might have a mix of commercial and retail customers.

For those with multiple campuses or facilities, the SDS must be transmitted with the first shipment of the chemical to each downstream location that receives the material; shipping the SDS to only one facility when the downstream customer has had the chemical delivered to multiple facilities is not in compliance.

For information on what OSHA inspectors look for with respect to transmission of SDS's, OSHA Instruction, Directive Number CPL 02-02-079 is your best resource. See http://www.ilpi.com/msds/osha/cpl0202079.html#G.1.p It discuses the electronic transmission I mentioned above in considerable detail.

Please follow up with any other questions you may have.

Best wishes,

Rob Toreki

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On Sep 13, 2016, at 12:13 PM, Lewis, Ronald L <Ronald.Lewis**At_Symbol_Here**TELEDYNE.COM> wrote:

To All,

I have read the OSHA requirements for supplying SDS information to institutions who order chemicals. It is a bit vague in exactly how and when the SDS is to be provided.

From your perspective, is a paper copy of the SDS required with each shipment? If the SDS is posted on the providers website, is that sufficient to satisfy availability? Is both required?

Thank you for your input.

Ron Lewis

Teledyne ISCO

Product Marketing Manager - Chromatography

4700 Superior Street

Lincoln, NE 68504

Direct 402-465-2076

Mobile 402-304-1511

www.ISCO.com/RF

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--- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org