Osha requirement for updating msds

As we know, OSHA adopted new hazardous chemical labeling requirements as a part of its revision of the Hazard Communication Standard (HCS), .1200, bringing it into alignment with the United Nations’ GHS.

These changes will help ensure improved quality and consistency in the classification and labeling of all chemicals, and will also enhance worker comprehension.

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Perceptions and misperceptions: I have encountered a number of people who request the H-Codes and P-Codes listed on their Safety Data Sheets. The codes are not included in GHS examples, and are absent in OSHA's HAZCOM 2012.

The Hazard HXXX codes and Precautionary PXXX codes are “intended to be used for reference purposes. Precedence rules allow some simplification, particularly related to the exclamation mark, which "should not appear" with the skull and crossbones, where the corrosive symbol is used for skin or eye irritation, or when the health symbol is used for sensitization or skin or eye irritation.

The best implementations of OSHA’s Hazard Communication standard (.1200) requirements for Safety Data Sheets followed the ANSI MSDS format (Z400.1).

GHS is the more recent best practice, first implemented in the EU and now by OSHA.

There has not been a recent change, at least in the last five years, in the recordkeeping standard on this matter.

I had also understood that the old MSDS needed to be kept for 30 years so am pleased to be able to dispose of them now.

We provide professional Safety Data Sheet (SDS) conversions and authoring to meet the new GHS and OSHA Hazcom 2012 requirements. OSHA's most-cited areas for small chemical producers are Respiratory Protection and Hazard Communication.

For larger producers it's the PSM standard, .119, for which OSHA has a National Emphasis Program.

The physical hazards section was led by the transportation sector, Health & Environmental by OECD and Hazard Communication by ILO.

Initially adopted in 2002, the current revision 7 was published August 2017; included are pictograms new to most users.

That’s what is was several years ago, Rose, and the OSHA compliance officer I called about it said it was for documenting exposure for health issues that took a long time to develop…That same 30 year retention was, and maybe still is, for BBP exposure records…….

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