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Ask the expert—PDR in place of MSDS file

Q: Instead of keeping an MSDS (Material Safety Data Sheets) file for our pharmaceuticals, couldn’t we just use the PDR (Physicians Desk Reference).

A: Replacing MSDS file with the PDR would make for a non-compliant alphabet soup for your hazardous drug policy, says OSHA. “Package inserts and the Physician’s Desk Reference cannot be accepted in lieu of MSDSs, as these documents do not meet the specification requirements of MSDSs under the present rule,” according to “Hazard communication standard and pharmaceuticals, [1] a 1994 OSHA interpretation letter.

Remember, that not all hazardous drugs require an MSDS.  Section (b)(6)(viii) of the standard [2] exempts  drugs, as defined by Federal Food, Drug, and Cosmetic Act, in solid, final form for direct administration to the patient (i.e., tablets, pills, capsules) from the MSDS requirement.

To help with MSDS questions, download the “Determining When an MSDS Is Necessary” [3]decision tree from the Tools page.