MSDS FAQ

Below are Frequently Asked Questions (FAQ) and answers about Material Safety Data Sheets (MSDSs), which are required by OSHA’s Hazard Communication Standard and Laboratory Safety Standard.

Please send any questions or comments to the ASU Industrial Hygiene Office, extension 6838, email cavanaughmm@appstate.edu

 

1. QUESTION: How do we decide if we even need to keep MSDSs?

ANSWER: OSHA does not clearly define all cases where MSDSs are required. To simplify this decision, use the following guidelines: MSDSs must be kept for all chemical products except those which meet all four of these criteria -- (1) general household or office product; (2) used for its intended purpose; (3) used in small quantities; and (4) used in a manner that is incidental to your work (i.e. infrequently, for short periods of time, and not one of your job duties). If in doubt, get an MSDS and/or call the Industrial Hygiene (IH) Office for help.

For example, use of whiteout when typing does not require an MSDS (meets all 4 criteria), but using whiteout as a flux when making jewelry does (not used for its intended purpose). Another example: if your job duties mostly involve landscaping but you keep a bottle of glass cleaner in your break room to keep the eating area clean, an MSDS is not required for the glass cleaner (though you must keep MSDSs for all the landscaping chemicals); on the other hand, if your main job is to keep offices clean, then you do need an MSDS for the glass cleaner, even if you only use a small spray bottle (use is not incidental to your job). Generally, if you are in doubt it's better to include MSDSs you aren't required to keep than to miss keeping ones you are required to keep. Don't forget to include MSDSs for any "free samples" a vendor may have given you. If you have questions, please do not hesitate to contact the IH Office.

Don't be mislead into thinking that all "chemical products" are liquids. Many are, but many of the items for which MSDSs may be required are not. For example, road salt, grass seed treated with pesticides, certain medicines (not any medicines brought in for personal use), and tanks of natural gas are all examples of chemical products for which an MSDS may be required. If in doubt, it is better to have MSDSs that are not required than to fail to have ones that are required.

2. QUESTION: I know we need to keep MSDSs, but how do I get them?

ANSWER: The best way to make sure you always have the most current MSDS is to either request an MSDS before ordering the product or to include one of the following statements in your Check Request (in the "Materials Required" section) or Purchase Order (in the "Description" section) when you order supplies (1) "SEND MSDS W/PRODUCT AND SHIP PRODUCT DIRECTLY TO [your name/address];" (2) "SEND MSDS TO [your name/address];" or (3) "SEND MSDS WITH PRODUCT."

If you order products through Check Requests or Purchase Orders and don't specify to whom MSDSs should be sent, many companies automatically send the MSDS to the Safety and Workers' Compensation Office. Since we have no way of knowing to whom the MSDS should be forwarded, the MSDS may likely never reach you.

Whenever possible, you should have hazardous products shipped directly to you so that the Warehouse does not have to manage the MSDSs or be involved with shipping potentially hazardous materials.

Requesting an MSDS before purchasing a product allows you to see if that product has hazards you might want to avoid. It may change your mind about purchasing the product. If a manufacturer is unwilling or unable to provide you with either an MSDS or a written statement that the product is not hazardous, then that is a good indication that you should look for a different product.<

If you already have the product but need an MSDS for it, try one of the websites below or contact the manufacturer (either look on the product packaging or ask Purchasing to find a manufacturer contact for you). Most manufacturers will fax or mail you an MSDS right away, and many large manufacturers of chemical products have MSDS websites for their products. If you have any trouble getting the manufacturer to send you an MSDS, you may need to write a letter requesting the MSDS so that you have documentation of your request in case OSHA ever inspects us. But a good rule of thumb is, if the manufacturer can't or won't supply you with an MSDS, you don't want to buy that product! If it is considered a nonhazardous product for which no MSDS is required (e.g. a product with no hazardous ingredients or that is packaged and intended for general household or office use), the manufacturer should be willing to tell you that in writing.

Finally, don't forget that these rules apply to "trial" and "free samples," too.

Here are some good websites from which you can print out or request MSDSs. All the internet addresses below were correct as of March 2000. If you have any trouble reaching a website listed below, please let the IH Office know.

http://hazard.com/msds/ “Vermont SIRI” site. One of the most complete MSDS collections on the web. You may be able to find your product more quickly if you know the CAS (Chemical Abstract Service) number or NSN (National Stock Number). All pure chemicals and many mixtures have been assigned CAS numbers; all MSDS must include the CAS number if there is one available.

http://www.msdssearch.com/ManuflinksA.htm “MSDS-Search” site. Connects you to MSDS websites of many manufacturers (some sites don’t have the actual MSDSs but allow you to request an MSDS via email, which is handy).

>http://www.msdssearch.com/DBLinksN.htm “MSDS-Search” site. Allows you to quickly search several MSDS databases on the web, including the “Vermont SIRI” site.

http://www.msdsprovider.net/msdslinks.nsf/search “MSDS Provider” site. Search for a manufacturer name (not a product name) to connect to the manufacturer’s MSDS website.

http://www.state.nj.us/health/eoh/rtkweb/rtkhsfs.htm “New Jersey Right to Know” site. Easy-to-read “plain English” descriptions of common chemicals and chemical products.

http://www.ilpi.com/msds/index.html “University of Kentucky” website. No MSDSs but many links to other websites. Also offers a nice glossary of MSDS terms.

http://www.hhmi.org/science/labsafe/lcss/lcss.html “Howard Hughes Medical Institute” site. Laboratory chemicals only. Very readable.

http://msds.pdc.cornell.edu/msdssrch.asp “Cornell University” site. Similar to the Vermont SIRI MSDS database.

3. QUESTION: Why doesn't the Safety Office just keep all the MSDSs? That way they'd all be in the same place?

ANSWER: The regulations for the Occupational Safety and Health Act (OSHA) require that MSDSs for products to which employees may be exposed to be readily available to those employees so that employees can stay informed about the hazards of the materials with which they work. Having to drive to the MSDS location, find a supervisor with a key to a locked file cabinet, or similar types of restrictions do not constitute "readily available." For that reason, MSDSs must be maintained at the job site.

There is only one exception to the requirement that MSDSs be maintained at the job site. For employees whose work is "roaming" in nature, OSHA allows MSDSs to be kept in a central location. However, the information on the MSDSs must be immediately available to the employee. By immediately available, OSHA means that the employee or an emergency responder must be able to call or radio in to someone where the MSDSs are stored and have the information read to them over the phone. That means that there must be a staffperson in the area where the MSDSs are stored at all times during all shifts.

As you already know, the MSDSs that were located in the Safety Office are now located in a locked cabinet outside the IH Office in the CAP (new science) building (the IH Office is part of, but not physically co-located with, the Safety Office). These copies serve only as an additional resource for the reasons discussed above. The Safety Office's MSDSs are organized alphabetically by product name. If you ever want to access the MSDSs outside the IH Office, the following people have keys to the cabinet: University Police (ext 2150); Evan Rowe in the Safety Office (ext. 6120); the Chemistry Department Office Manager (ext. 3010), and Mary Cavanaugh, the University Industrial Hygienist (ext. 6838).

4. QUESTION: Then why send a copy of MSDSs to the Safety Office at all?

ANSWER: There is no requirement to send a copy of your MSDS book to the Safety Office, unless we specifically ask you for a copy. It is handy for the Safety Office to have a copy of the book, however, as much of the work that the IH Office does is based on the potential chemical exposures of the workplace. Having a copy of your MSDS book helps the IH Office identify the general types of chemicals your department uses. In addition, it provides a possible backup copy in case of an emergency (more on this later!). If you choose to put your MSDSs on your departmental website (see more at Question 14), then you could simply provide the IH Office with the website address.

5. QUESTION: We keep our MSDSs in the main administrative office. Is that okay?

ANSWER: Yes, as long as the MSDSs are available to all your employees during all their work shifts. However, it is even better if you can keep the MSDSs in the work area where the hazardous products are actually used. It is a good idea to keep one complete set in a file cabinet so that you can make a copy if the main MSDS book is lost or damaged.

If it is not reasonably convenient to keep MSDSs in the area where the hazardous materials are used, it is okay to keep them in a central office, break room, warehouse, or other location as long as that office is accessible to all employees who are exposed to the products during all shifts. Thus if your department has a graveyard shift, MSDSs must not be kept in either an unlocked area or an area to which all shift employees have a key. Employees should not have to ask the secretary or supervisor to unlock the room, cabinet, etc. where the MSDSs are kept; this amounts to having to ask for permission to access MSDSs, which goes against the intent of the OSHA regulations.

For employees who spend most of their time at a variety of locations, such as Zone Maintenance and Landscaping, keeping MSDSs in a central location is allowed. Again, however, the MSDSs in that central location must be immediately available during all shifts. This means that the area where the MSDSs are kept must be staffed at all times and reachable by phone, pager, radio, etc. Your department may find it more reliable to keep a current MSDS book in the vehicles of "roaming" staff.

6. QUESTION: Why do we have to keep MSDSs at the job site?

ANSWER: If you have an injury, spill, or fire, having those MSDSs readily available to you and those around you must control the emergency could save your life. This is one of the reasons OSHA requires MSDSs to be maintained at the job site.

The other reason is so that employees can educate themselves about the risks of a product before they use or are otherwise exposed it, or look up potential health effects of products in case they suspect they may be exposed to unhealthy levels of chemicals. Because some employees may feel uncomfortable if his/her boss knows they are looking at an MSDS, one intent of OSHA's requirements is to prevent situations in which an employee must ask for permission to see an MSDS. For example a locked filing cabinet to which only certain people have a key would not be an ideal setup.

All departments are also encouraged to indicate where their MSDSs are stored on their written fire escape route plans, as long as doing so will not interfere with the legibility of the plan.

7. QUESTION: The only central area we have is locked at night and we have a night crew. What do we do?

ANSWER: There are several ways to make MSDSs available in this situation. You can attach a shelf or one of those plastic "hot boxes" on the wall outside the central office or on the door of the office, and keep the MSDS book in there. If you think it might get misplaced, use a thin chain to secure it. You can chain the book to a wall or table, like phone books are chained to pay phone stands. There may be fire safety issues related to where you locate the book, so before installing any of the above suggestions please call our Safety Inspector, Beth Clark, at extension 4007. If you are stumped and need additional suggestions on where to locate the MSDS book, feel free to call the IH Office.

8. QUESTION: I work in a laboratory; are there any special MSDS requirements that apply to me?

ANSWER: Yes. If you ship any chemicals to another party, you essentially become a "manufacturer" in OSHA's eyes, so you must label the container and provide an MSDS with the shipment. If a substance is produced in and for exclusive use of the lab, then you do not need an MSDS but you do need to determine if it is hazardous and train potentially exposed people accordingly. Don't forget to include items treated with chemicals, such as lab specimens, as well as pure chemicals. If the substance is a reaction intermediate or byproduct whose composition is not known, then MSDSs are not required but you must assume it is hazardous. You also should label the secondary container (flask, beaker, etc.) into which you transfer a chemical with the identity of the chemical.

Don't forget that you must make others who might be exposed to the chemicals aware of the hazards and the location of the MSDSs (e.g., a plumber working on the pipes, a ventilation contractor working on the hood ductwork). This requirement applies to non-lab workplaces too, but labs are particularly likely to have unusual hazards that should be conveyed to non-lab employees.

Also, remember that labs are subject not only to the requirements in the Hazard Communication Program but also the requirements in ASU's Chemical Hygiene Plan.

9. QUESTION: I work in a stockroom/warehouse. Do we have to keep MSDSs?

ANSWER: Yes and no. OSHA gives a break to stockrooms, warehouses, and other places where all chemicals are in sealed containers. You do not have to actively seek MSDSs for all products handled in the warehouse. You only have to keep MSDSs that arrive with the shipment or any MSDSs requested by an employee in the warehouse.

This only applies to products that are in a sealed container, though. If you transfer bulk products to smaller containers, for example, you must have an MSDS. Any chemicals you use or may otherwise be exposed to that meet the four criteria in Question 1 also require an MSDS.

10. QUESTION: Do we have to have MSDSs for medicines?

ANSWER: Probably not, though it depends on the intended use of the medicine and its physical form. It is unlikely that any place other than perhaps Student Health Services would need MSDSs for medicines. You do not need an MSDS for food, drugs, and cosmetics brought into the workplace for employee consumption.

In Student Health Services, there is a possibility that some medicines might need MSDSs. OSHA does not require an MSDS for over-the-counter drugs in their original packaging, regardless of whether they are in solid, liquid, or gaseous form. MSDSs are not required for prescription medicines in solid, final form intended for administration to the patient (e.g. a pill or capsule), or any medicine dispensed from a pharmacy to a health care provider for direct administration to the patient. MSDSs are required for prescription drugs that are in liquid or gaseous form (unless they meet previously mentioned exceptions, i.e. the drugs are not intended for employee consumption or will be administered directly to the patient. MSDSs also are required for prescription drugs that are solids but not in their final form: for example, powdered drugs that are mixed with water to make an oral suspension.

11. QUESTION: What do I do if I or a fellow worker is injured or becomes ill, and I suspect it may be because of a chemical product they are using on the job?

ANSWER: If it is an emergency, call extension 8000 and get the necessary medical help. Grab the MSDS book and send it with the injured person or give it to the emergency medical personnel (don't delay emergency attention to get the MSDS book -- you can always send the book over or fax the appropriate pages a few minutes later). If the victim is incoherent or unconscious, be sure someone indicates which particular MSDSs in the MSDS book are applicable to the injury. The information in the MSDS could save that person's life, or minimize the damage of his/her injuries.

If you can transport yourself, bring the MSDS book with you (or a copy of the applicable MSDS, if there is time to make copies). Since taking the MSDS book away from the job site leaves your fellow employees without the book, this is another good reason to maintain a backup copy in a secure location. This is also why the MSDS book should clearly indicate which department it belongs to and include a phone number.

12. QUESTION: Keeping up with MSDSs sounds complicated. What sort of filing system should I use?

ANSWER: It's actually much easier than it sounds.

a. When a new product arrives, either date the MSDS, or add the product and date to your chemical inventory list. Month and year (or even year only if you don't know the month) are sufficient. Make sure you put the date you started using the product, not the date you received the MSDS.
b. Keep current MSDSs in an easy-to-find place that all employees can access during all shifts.
c. When you stop using that product, date it again with "stopped using on [month/year or year only]" and move the old MSDS to another folder, binder, or a separate section of the MSDS binder. Or, update your chemical inventory list with the date you stopped using the product and discard the out-of-date MSDS. Noting the date you begin using and stop using the chemical is important and will help ASU meet OSHA requirements.

One of the simplest and most effective ways to keep MSDSs is a 3-ring binder. Some people like to insert each page into a plastic page protector. Make all pages of each MSDS are either stapled together or can be identified; it's not uncommon for MSDS books to drop on the floor and the pages go flying (this knowledge is from personal experience!). The Safety Office (ext. 4007) still has a number of 3-ring binders and plastic sheet protectors available for free to any department who needs them. If you have a lot of chemical products, using tabbed dividers or colored paper to separate them into groups is handy. The best ways to sort MSDSs into groups is either by the way the products are used in your area (e.g. cleaning supplies, painting products, welding materials, etc.) or by the location where they are used (e.g. electrical shop, woodworking classrooms, etc.). Whatever results in the least duplication and yet makes sense to you. If you have any trouble, feel free to call the IH Office for help.

Some people use accordion files, regular filing cabinets, even computers (as long as all affected employees know how to use the computer) instead of the traditional ring-binder notebook. Whatever way you choose, be sure that the book/file/etc. is clearly labeled "MSDS (or "Material Safety Data Sheets")" and include a contact name and phone number.It's important to include the department name and a point-of-contact phone number on or inside the book in case the book is ever misplaced.

13. QUESTION: Do I need to save old MSDSs?

ANSWER: You must either save old MSDSs, or save the list of chemicals used in your workplace, for at least 30 years. Although keeping a list of chemicals is generally preferred, it is sometimes impractical. An acceptable alternative is to keep old MSDSs and write on them the dates you started and stopped using the products.

Rather than keeping these old MSDSs in your main MSDS book, however, it would be less confusing to keep them in a separate file, or at least in a separate section of the MSDS book.

All lists of chemicals (or old MSDSs if you choose that option) must be kept for at least 30 years after you stopped using the product.

14. QUESTION: Why don't we just put all our MSDSs on a central computer system and do away with the paper?

ANSWER: Computer-stored MSDS systems have become very popular for obvious reasons, and ASU may gradually move towards this option. However, there are two potential drawbacks that make computer-stored systems better as a backup system at this time here at ASU.

First, you can only meet OSHA's requirement for ready access if all employees have access to a computer and know how to access the MSDSs from the computer. Although we are making great strides in increasing computer availability and literacy at the university, there are people who may be exposed to chemicals as part of their jobs who do not have access to a computer, or who might not feel confident enough of their computer skills to access an MSDS database retrieval system. Second, if the university's server is down, there is a fire, etc., then you can't access computer-based MSDSs. Although OSHA allows computer-based systems, many N.C. OSHA compliance officers generally favor MSDSs in old-fashioned paper form for these very reasons.

If you like the idea of a computer-based system, however, you can create a simple one of your own at virtually no cost by scanning your MSDSs and linking them on your departmental website. Information Technology Services offers free training on how to publish and edit websites. A system like this would not have the sophisticated searching and organizing capabilities of pre-programmed MSDS database systems, but it might serve your department quite well. Keep in mind, however, that all affected employees in your department would have to have both immediate, unfettered access to and the necessary knowledge or training to access the MSDSs. Also, you should maintain the MSDSs on the website just as you would MSDSs on paper: date them before scanning them in; remove outdated MSDSs from the website; date them when you stop using the product; and save the chemical inventory list(s) or old MSDSs in a separate file/web link.

You might be interested to know that there are a number of websites that offer free MSDSs that you can print right out at your computer. These sites are usually managed by the product manufacturers or by a university. Several of the most popular sites are listed after Question 2 of this FAQ Sheet.

15. QUESTION: Well, now I know more about MSDSs than maybe I ever really wanted to know! Can you summarize this information for me?

ANSWER: Why yes, what a great idea! ASU has a newly-created MSDS Checklist to provide a quick way to help you decide if you need to maintain MSDSs and how to maintain them. This checklist is available upon request (email or call the IH Office), or by clicking on the link called "Material Safety Data Sheet Checklist." This link is found on the previous web page you visited. You may print out the checklist. After doing so, return to this web site by clicking on the "back" button on your web browser.


References:

North Carolina Occupational Safety and Health Standards for General Industry Part 1910 (NCOSHA 1910), Section 1200, Hazard communication.

NCOSHA 1910, Section 1450, Occupational exposure to hazardous chemicals in laboratories.

Telephone conversations with North Carolina Department of Health and Human Services, March 2000.

Telephone conversations with North Carolina OSHA Consultative Services and Compliance Officers, March 2000.

(Last updated 11/01/02)

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