Ask the expert: How long to retain old MSDSs

By: September 16th, 2010 Email This Post Print This Post

Q: How long do you have to keep MSDS files for products no longer used in the health center? I did not see that information on the Safety Recordkeeping Requirement sheet on the Tools page.

A: You don’t need to keep MSDSs for products no longer in use.

Keep in mind however that you do need to keep either the MSDS, 1910.1020(c)(5)(iii), or a “chemical inventory or any other record which reveals where and when used and the identity (e.g., chemical, common, or trade name) of a toxic substance or harmful physical agent,” 1910.1020(c)(5)(iv), according to the OSHA Access to Employee Exposure and Medical Records standard.

Comments

When I researched this information it stated that MSDS records for chemicals no longer used must be kept for 30 years.

Just type in MSDS retention time.

By carl malmberg on September 28th, 2010 at 12:45 pm

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…….

Nowhere does OSHA say that an old or discontinued MSDSs must be kept for 30 years. The recordkeeping reference in the post above says only that the MSDS or information from the MSDS that is part of an exposure incident must be kept for 30 years as part of the exposure or medical record.

By carl malmberg on October 5th, 2010 at 10:20 am

That’s ok by me. The federal representative(s)at the time were saying all old MSDS were to be kept for 30 years, for the reason I mentioned above. Perhaps he misinterpreted. He likened it to the requirement for keeping needlestick records for 30 years or more. Have they modified that, also?

Thanks for your input.

By David LaHoda on October 5th, 2010 at 10:31 am

Carl:

Thanks for bring out the details of this matter for discussion.

Like a needlestick, which is an exposure record, an incident involving a hazardous substance remains on file for 30 years and the pertinent information from the MSDS, not necessarily the MSDS itself, is part of the exposure record. MSDSs not associated with a specific exposure incident would not need to be retained.

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. This is the reason I continue to appreciate your expertise and subscribe to the “Update.” Thanks.

By AGC of North Dakota on September 18th, 2013 at 2:21 pm

What David said is what OSHA has also stated in a letter of interpretation from 2002. https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24255

Here is the relevant blurb from the LOI

“…the content of a record determines if it is an employee exposure record, not the title of the document. For example, the definition provided by 1910.1020(c)(5) includes “material safety data sheets indicating that the material may pose a hazard to human health.” A material safety data sheet (MSDS) indicating no hazard to human health would not be considered an employee exposure record.”

 

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