Guest guest Posted April 27, 2004 Report Share Posted April 27, 2004 >does anyone have a " polite " way to request MSDS sheets from a company they >have purchased from, and were told they couldn't have them. A MSDS is required by OSHA regulations. Demand excellence... Expect excellence... BACKGROUND OSHA's Hazardous Communication Standard (29CFR1910.1200) was created " to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training. " Section 1910.1200( of the Hazardous Communication Standard requires chemical manufacturers or importers to assess the hazards of chemicals which they produce or import, and all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, material safety data sheets, and information and training. The OSHA rules defines a chemical manufacturer as " an employer with a workplace where chemical(s) are produced for use or distribution. " Section 1910.1200(g)(6)(i) of the Hazardous Communication Standard states " Chemical manufacturers or importers shall ensure that distributors and employers are provided an appropriate material safety data sheet with their initial shipment, and with the first shipment after a material safety data sheet is updated " . In a letter addressed to Regulatory Affairs group at DIFCO Laboratories, the Director of OSHA's Office of Health Compliance Assistance wrote: " The standard requires the MSDS to be provided to the downstream user(s) by the chemical manufacturer or importer. Your system requires the MSDS to be sought out by the downstream user(s). This responsibility under the standard cannot be transferred to the downstream user(s). " This letter can be found at: http://www.ilpi.com/msds/osha/I19940831A.html and quoting from http://www.ilpi.com/msds/faq/partb.html#downstream " The OSHA Hazard Communication Standard 29 CFR 1910.1200 requires a " downstream flow " of information. For example, the original manufacturer or importer, Employer A, must create an MSDS for any hazardous chemical that they produce. When they ship that to a commercial customer or distributor, Employer B, they must send the MSDS to Employer B. If Employer B then ships the chemical to another firm, Employer C, it is Employer B's responsibility to pass the MSDS " downstream " to Employer C. In other words, the information flows: Employer A ----> Employer B ----> Employer C According to this OSHA interpretation titled The acceptability of your " FAX-on-demand " system for providing copies of material safety data sheets (MSDS): Your primary obligation in supplying MSDSs is to your direct customers, that is, your distributors. You must provide a copy of the MSDS with the first shipment to each of your direct customers, and, if the MSDS for one of your products is updated, you must send the updated MSDS with the next shipment of the product to that direct customer. Your distributors are, in turn, responsible for supplying a copy of the MSDS with the first shipment to each of their direct customers, and so on... However, because this chain of information transmission through the distributor can sometimes be broken, OSHA has added the requirement that manufacturers must provide a copy of the MSDS to other " downstream " employers upon request. Your " FAX-on-demand " system can be used to fulfill this requirement. Please refer to revised language in paragraphs (g)(6) and (g)(7) of the standard for additional clarification on requirements for providing MSDSs. In general, if you need an MSDS, you should get it from your " upstream " supplier. If that is not possible, then the manufacturer must supply one on request (as long as you are an employer that requires an MSDS under the Hazard Communication Standard). What is the problem with supplying Material Safety Data Sheets to your customers? It's there right to know. Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 27, 2004 Report Share Posted April 27, 2004 >does anyone have a " polite " way to request MSDS sheets from a company they >have purchased from, and were told they couldn't have them. A MSDS is required by OSHA regulations. Demand excellence... Expect excellence... BACKGROUND OSHA's Hazardous Communication Standard (29CFR1910.1200) was created " to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training. " Section 1910.1200( of the Hazardous Communication Standard requires chemical manufacturers or importers to assess the hazards of chemicals which they produce or import, and all employers to provide information to their employees about the hazardous chemicals to which they are exposed, by means of a hazard communication program, labels and other forms of warning, material safety data sheets, and information and training. The OSHA rules defines a chemical manufacturer as " an employer with a workplace where chemical(s) are produced for use or distribution. " Section 1910.1200(g)(6)(i) of the Hazardous Communication Standard states " Chemical manufacturers or importers shall ensure that distributors and employers are provided an appropriate material safety data sheet with their initial shipment, and with the first shipment after a material safety data sheet is updated " . In a letter addressed to Regulatory Affairs group at DIFCO Laboratories, the Director of OSHA's Office of Health Compliance Assistance wrote: " The standard requires the MSDS to be provided to the downstream user(s) by the chemical manufacturer or importer. Your system requires the MSDS to be sought out by the downstream user(s). This responsibility under the standard cannot be transferred to the downstream user(s). " This letter can be found at: http://www.ilpi.com/msds/osha/I19940831A.html and quoting from http://www.ilpi.com/msds/faq/partb.html#downstream " The OSHA Hazard Communication Standard 29 CFR 1910.1200 requires a " downstream flow " of information. For example, the original manufacturer or importer, Employer A, must create an MSDS for any hazardous chemical that they produce. When they ship that to a commercial customer or distributor, Employer B, they must send the MSDS to Employer B. If Employer B then ships the chemical to another firm, Employer C, it is Employer B's responsibility to pass the MSDS " downstream " to Employer C. In other words, the information flows: Employer A ----> Employer B ----> Employer C According to this OSHA interpretation titled The acceptability of your " FAX-on-demand " system for providing copies of material safety data sheets (MSDS): Your primary obligation in supplying MSDSs is to your direct customers, that is, your distributors. You must provide a copy of the MSDS with the first shipment to each of your direct customers, and, if the MSDS for one of your products is updated, you must send the updated MSDS with the next shipment of the product to that direct customer. Your distributors are, in turn, responsible for supplying a copy of the MSDS with the first shipment to each of their direct customers, and so on... However, because this chain of information transmission through the distributor can sometimes be broken, OSHA has added the requirement that manufacturers must provide a copy of the MSDS to other " downstream " employers upon request. Your " FAX-on-demand " system can be used to fulfill this requirement. Please refer to revised language in paragraphs (g)(6) and (g)(7) of the standard for additional clarification on requirements for providing MSDSs. In general, if you need an MSDS, you should get it from your " upstream " supplier. If that is not possible, then the manufacturer must supply one on request (as long as you are an employer that requires an MSDS under the Hazard Communication Standard). What is the problem with supplying Material Safety Data Sheets to your customers? It's there right to know. Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 27, 2004 Report Share Posted April 27, 2004 Is MSDS something I can require of my retail mica supplier? I asked and was told by one company that I didn't need it for labeling. The other supplier (Joan at SweetScents) spent a lot of time making me MSDS sheets and bent over backwards. Angie Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 27, 2004 Report Share Posted April 27, 2004 Even you local grocery store has the MSDS for things like Milk, Mayo, etc. It becomes a Hazmat problem if it is spilled. Everything you order should have MSDS with it. Especially if you have a shop. You need to have them posted. Everything I have shipped to hubby so it is cheaper, has to have MSDS posted to the outside of the box. It is mandatory. I'll ask him the specific regulation or look it up in his Hazmat regs. I have copies of all my MSDS at the local fire station. That way if anything happens, they will know what to do. Too many things become hazardous when they are mixed with other things. Luck is preparation meeting opportunity. ~ Ellen D. ~ ----- Original Message ----- From: chris@... I thought this only pertains to the actual manufacturer and not the reseller. It also depends on the State they are located in and their regulations. This is what I was told Anyone know? Chris Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 27, 2004 Report Share Posted April 27, 2004 Even you local grocery store has the MSDS for things like Milk, Mayo, etc. It becomes a Hazmat problem if it is spilled. Everything you order should have MSDS with it. Especially if you have a shop. You need to have them posted. Everything I have shipped to hubby so it is cheaper, has to have MSDS posted to the outside of the box. It is mandatory. I'll ask him the specific regulation or look it up in his Hazmat regs. I have copies of all my MSDS at the local fire station. That way if anything happens, they will know what to do. Too many things become hazardous when they are mixed with other things. Luck is preparation meeting opportunity. ~ Ellen D. ~ ----- Original Message ----- From: chris@... I thought this only pertains to the actual manufacturer and not the reseller. It also depends on the State they are located in and their regulations. This is what I was told Anyone know? Chris Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 27, 2004 Report Share Posted April 27, 2004 Even you local grocery store has the MSDS for things like Milk, Mayo, etc. It becomes a Hazmat problem if it is spilled. Everything you order should have MSDS with it. Especially if you have a shop. You need to have them posted. Everything I have shipped to hubby so it is cheaper, has to have MSDS posted to the outside of the box. It is mandatory. I'll ask him the specific regulation or look it up in his Hazmat regs. I have copies of all my MSDS at the local fire station. That way if anything happens, they will know what to do. Too many things become hazardous when they are mixed with other things. Luck is preparation meeting opportunity. ~ Ellen D. ~ ----- Original Message ----- From: chris@... I thought this only pertains to the actual manufacturer and not the reseller. It also depends on the State they are located in and their regulations. This is what I was told Anyone know? Chris Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 27, 2004 Report Share Posted April 27, 2004 >I thought this only pertains to the actual manufacturer and not the >reseller. >and quoting from http://www.ilpi.com/msds/faq/partb.html#downstream > > " The OSHA Hazard Communication Standard 29 CFR 1910.1200 requires a > " downstream flow " of information. For example, the original >manufacturer or importer, Employer A, must create an MSDS for any >hazardous chemical that they produce. When they ship that to a >commercial customer or distributor, Employer B, they must send the MSDS >to Employer B. If Employer B then ships the chemical to another firm, >Employer C, it is Employer B's responsibility to pass the MSDS > " downstream " to Employer C. In other words, the information flows: > >Employer A ----> Employer B ----> Employer C Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 27, 2004 Report Share Posted April 27, 2004 >I thought this only pertains to the actual manufacturer and not the >reseller. >and quoting from http://www.ilpi.com/msds/faq/partb.html#downstream > > " The OSHA Hazard Communication Standard 29 CFR 1910.1200 requires a > " downstream flow " of information. For example, the original >manufacturer or importer, Employer A, must create an MSDS for any >hazardous chemical that they produce. When they ship that to a >commercial customer or distributor, Employer B, they must send the MSDS >to Employer B. If Employer B then ships the chemical to another firm, >Employer C, it is Employer B's responsibility to pass the MSDS > " downstream " to Employer C. In other words, the information flows: > >Employer A ----> Employer B ----> Employer C Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
Guest guest Posted April 27, 2004 Report Share Posted April 27, 2004 >I thought this only pertains to the actual manufacturer and not the >reseller. >and quoting from http://www.ilpi.com/msds/faq/partb.html#downstream > > " The OSHA Hazard Communication Standard 29 CFR 1910.1200 requires a > " downstream flow " of information. For example, the original >manufacturer or importer, Employer A, must create an MSDS for any >hazardous chemical that they produce. When they ship that to a >commercial customer or distributor, Employer B, they must send the MSDS >to Employer B. If Employer B then ships the chemical to another firm, >Employer C, it is Employer B's responsibility to pass the MSDS > " downstream " to Employer C. In other words, the information flows: > >Employer A ----> Employer B ----> Employer C Maurice -------------------------------------------------------- Maurice O. Hevey Convergent Cosmetics, Inc. http://www.ConvergentCosmetics.com ------------------------------------------------------- Quote Link to comment Share on other sites More sharing options...
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