On Mar 23, 2018, at 3:06 PM, Edward Movitz <movitz**At_Symbol_Here**OLEMISS.EDU> wrote:--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchasAs a state agency, with state materials used by state employees - the occupational safety regulations do not require us to have or distribute MSDS, SDS or any data information sheets. Since we do not have any, we can not supply any to the LEPC.Section 311 requires facilities that have MSDSs for chemicals held above certainthreshold quantities to submit either copies of their MSDSs or a list of these chemicalsto the SERC or TERC, LEPC, and local fire department.As a side note, part of our campus is in the city, and part is in the county. Two different emergency management systems and two sets of regulations and policies.EdEdward M. MovitzResearch & Environmental Compliance Officer / FSOThe University of MississippiLaboratory Services100 Health and Safety BuildingP.O. Box 1848University, MS 38677-1848U.S.A.O:+1-662-915-5433 | F: 662-915-5480Please Consider the Environment before printing this Email.Confidentiality Note: The information contained in this e-mail and/or document(s) attached is for the exclusive use of the individual named above and may contain confidential and privileged information. If you are not the intended recipient, please immediately delete this message and all copies of it from your system. You are hereby notified that you are strictly prohibited from reading, photocopying, distributing or otherwise using this e-mail or its contents in any way. If you have received this transmission in error, please notify the sender immediately.From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>
Sent: Friday, March 23, 2018 1:44 PM
Subject: [DCHAS-L] SDS requirementsA quick question, perhaps:
Am I correct that SDS's are required only by OSHA to support employer's safety programs for their employees. That is, if there is no employer-employee relationship, hazard information doesn't need to follow OSHA format requirements?
The reason I ask is that I know, for example, EPA requires MSDS's be supplied to LEPCs and emergency responders upon request. Of course, as with any EPA regulation, state and local interpretation and enforcement practices vary widely.
Thanks for any insight on this.
Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
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