Question of the Week: When Do I have to Update My Material Safety Data Sheets?

Posted on 6/7/2011 by James Griffin

UPDATE: This post was written in June 2011, just before OSHA officially adopted the Globally Harmonized Standard for Classifying and Labeling Chemicals, or GHS for short.

The final deadline for compliance with GHS workplace hazcom rules was June 1, 2016. By that date, employers whose workers are exposed to hazardous chemicals were required to update their workplace hazard communication system and provide additional training on any newly identified GHS hazards. Click here to find out more about OSHA's incorporation of GHS standards into the 1910.1200 hazard communication Standard. 
Need to update your workplace’s HazCom plan? The Managing Hazard Communication Online Course will guide you through how GHS standards will change the way you protect employees from chemical hazards.

Need GHS-compliant hazcom training for employees? The Hazard Communication Online Course is designed to help employees identify, mitigate, and avoid the chemical hazards they face on the job, including changes under the adopted GHS rules.  

Read more about GHS hazard communication here: Valuable Insights in Latest OSHA GHS Enforcement Memo or see all of our GHS posts since 2011.

Original Post (June 2011)

Q. Under the Hazard Communication Standard (29 CFR 1910.1200), the Occupational Safety and Health Administration (OSHA) requires manufacturers and importers to obtain or develop material safety data sheets (MSDS) for each hazardous chemical they produce or import. Manufacturers and importers must provide these MSDS to distributors and employers with their initial shipment, and with the first shipment after the MSDS are updated.
How often does OSHA require manufacturer/importers to update their MSDS?
A. Under the current Hazard Communication Standard, manufacturers and importers must ensure that the information on the MSDS “accurately reflects the scientific evidence used in making the hazard determination.” Whenever they become aware of any significant new information regarding the hazards of the chemical, or ways to protect against the hazards, they must update the MSDS within 3 months. If the chemical is not currently being produced or imported, the MSDS must be updated before the chemical is introduced into a workplace again. [29 CFR 1910.1200(g)(5)]
However, manufacturers and importers may soon need to update all of their Material Safety Data Sheets even though the hazards of the chemicals may not change. This is because before the year is out, OSHA intends to finalize changes to the Hazard Communication Standard, and other relevant chemical standards, to harmonize domestic regulations with the Globally Harmonized System of Chemical Classification and Labeling (GHS). 
Once the Standard is revised, all Material Safety Data Sheets will have to be replaced with Safety Data Sheets (SDS) within 3 years. The revised Standard will specify the format, order, layout, and information that appears on a SDS where the old format only specified the information that must appear. Because the GHS system for SDS was based on an existing industry consensus standard (ANSI Z400.1), and because many countries have already adopted the GHS in whole or in part, many larger international companies will find themselves already in compliance with the GHS. Small- and medium–sized enterprises and businesses new to the international market, on the other hand, are more likely to have some catching up to do.

Tags: GHS, HazCom, osha, Safety Data Sheets

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