Jump to content
RemedySpot.com

RE: RE: MSDS

Rate this topic


Guest guest

Recommended Posts

Guest guest

>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(B) 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

-------------------------------------------------------

Link to comment
Share on other sites

Guest guest

>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(B) 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

-------------------------------------------------------

Link to comment
Share on other sites

Guest guest

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

Link to comment
Share on other sites

Guest guest

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

Link to comment
Share on other sites

Guest guest

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

Link to comment
Share on other sites

Guest guest

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

Link to comment
Share on other sites

Guest guest

>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

-------------------------------------------------------

Link to comment
Share on other sites

Guest guest

>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

-------------------------------------------------------

Link to comment
Share on other sites

Guest guest

>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

-------------------------------------------------------

Link to comment
Share on other sites

Join the conversation

You are posting as a guest. If you have an account, sign in now to post with your account.
Note: Your post will require moderator approval before it will be visible.

Guest
Reply to this topic...

×   Pasted as rich text.   Paste as plain text instead

  Only 75 emoji are allowed.

×   Your link has been automatically embedded.   Display as a link instead

×   Your previous content has been restored.   Clear editor

×   You cannot paste images directly. Upload or insert images from URL.

Loading...
×
×
  • Create New...