We do not always purchase specific chemicals such as acetone, xylene, etc., from the same manufacturer or supplier, and each manufacturer supplies a Material Safety Data Sheet for its chemicals. Is it necessary to keep copies of all MSDSs from each company, or will one complete MSDS suffice for routine purposes, emergency situations or both? Answered by Robert A. Ernst, associate editor – workplace safety, J.J. Keller & Associates Inc., Neenah, WI.
OSHA's Hazard Communication Standard [29 CFR 1910.1200(g)] states, "Employers shall have a Material Safety Data Sheet in the workplace for each hazardous chemical which they use." According to the agency, the key to complying with the standard is ensuring employees have no barriers to accessing the information contained in the MSDS during all workshifts.
However, HCS is a "performance-oriented" standard, meaning OSHA has specified the required outcomes but has left the decisions on how to accomplish those outcomes to the employer. According to OSHA, "Given the performance-oriented nature of the standard, an employer must be certain that employees are provided all the necessary information concerning the hazards of chemicals in the workplace."
OSHA has approved, in principle, the idea of using a single MSDS for the same type of chemical made by different manufacturers, although the agency has "a number of concerns with the approach," according to an OSHA Letter of Interpretation, "09/08/2004 – Responsibility of the Employer and Manufacturer to Present Consistent Information Between the Labels and Material Safety Data Sheets."
In the letter, OSHA says an employer can use a single MSDS for one type of chemical made by different manufacturers, provided:
- The employer ensures that the specific identity on the MSDS can be cross-referenced to the corresponding label of the hazardous chemical containers
- During hazard communication training, employees are informed of the practice of using one MSDS as representative of all vendors
- The MSDS the employer selects must have complete and accurate information as required by section (g)(3) of the Hazard Communication Standard
- The MSDS contains the name, address and telephone number of the party who prepares or distributes the MSDS
The party listed must be able to provide information on the hazardous chemicals or clarification of the information on the MSDS, as well as emergency procedures, if necessary, in lieu of the actual manufacturer. A chemical manufacturer, importer or distributor may not wish to, and is not required to, act as the responsible party for a chemical it did not produce.
Go to osha.gov to read OSHA's Letter of Interpretation, "09/08/2004 – Responsibility of the Employer and Manufacturer to Present Consistent Information Between the Labels and Material Safety Data Sheets."