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Wiping out a surveyor’s MSDS Wite-Out mistake

I recently received a fairly common question with a slight twist to it. Many people wonder if common household items such as Wite-Out© need to have a material safety data sheet (MSDS) on file. Although OSHA doesn’t require an MSDS in this case, this particular person said that a Joint Commission surveyor indicated otherwise.

This is not only interesting from an empirical standpoint, it is also interesting from a pure standards-compliance standpoint. The surveyor that indicated that The Joint Commission requires a MSDS for such products was completely and utterly incorrect in that assertion. TJC is not in the business of increasing the scope of federal regulations, and has not, in fact, done so in this or any other similar finding.

My consultative advice would have been to clarify the finding as your practice is absolutely within the expectations and requirements of the standards. Unfortunately for you, this was a gross over-interpretation by the surveyor.

What you might want to do is to submit the practice as a question to the Standards Interpretation Group (basically, “We do not maintain MSDS’s for certain products, like Wite-Out® or nail polish remover, that are used in accordance with “normal” usage – is this compliant with Joint Commission standards?) I believe that the response will indicate that TJC does not specify in either direction beyond requiring you to manage risk in accordance with regulatory requirements. Having this response on the record will help to prevent future survey over-interpretations (at least in this regard).

Editor’s note. This post originally appeared in Mac’s Safety Space [1], [1]September 2, 2010, as “Will surveyors require an MSDS for Wite-Out?”