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.
Q: When I look at my bottle of Wite-Out®, it states that it is flammable and that people should avoid prolonged skin contact and breathing vapors. This sounds to me like an MSDS is needed.
A: Consumer products used in accordance with the label are not generally considered under the hazard communication standard. In fact, an OSHA letter of interpretation specifically addresses office chemicals saying:
Q: Must a medical practice create a list of all hazardous substances used in the workplace? It seems as if the MSDS file already covers that information.
Q: For my material safety data sheet (MSDS) files, I separate chemicals from the injectable hazardous drugs. Is this OK with OSHA?
Q: Please state the regulation allowing the removal of a chemical/medication from it’s original container and placing it into another “unmarked” container for a “small” amount of time and then using it. What defines a “small” amount of time?
A: First of all the OSHA regulation you allude to is only for hazardous chemicals. I know of none for unlabeled medications, as would be expected.
Q: Is it okay to have material safety data sheet (MSDS) computer files instead of paper files?
A: If employees can obtain MSDS information while in the work area, computer MSDS files meet the accessibility requirements, according to an OSHA fact sheet concerning the hazard communication standard.
Q: Is receiving material safety data sheet (MSDS) information by telephone an adequate backup for an electronic MSDS system?
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.
Q: Is putting our material safety data sheet (MSDS) binder online in compliance with OSHA?
Q: Our office decontaminates used instruments overnight in an unmarked basin. Is this an OSHA violation?
Q: To clean out my files, may I eliminate material safety data sheets (MSDS) for household products such as soaps and cleaners without incurring an OSHA violation?
A: You can do without MSDS for consumer products commonly used in the workplace if employees use the products according to the label.
Q: What is the standard volume for “large” and “small” spills?
A: Sometimes the rule of thumb on this question is that you can consider anything 1 gal or less a small spill, and everything above 1 gal a large spill. However, depending on what materials are in question, you might need to make adjustments.