MSDS requirement

[rexfire]

On some of our products we give out a small can of touch up paint in an aerosol spray can. Are we required to give the customers an MSDS along with this? I get the MSDS from the manufaturer when it comes to us, but we do not give an MSDS when we pass it on to our customers?

 

[tomwalz]

Probably should.

Have it available anyway.

I have MSDS sheets for hand soap in the restrooms and dishwasher soap in the lunchrooms. I occasionally, but rarely, have had a brand new, extremely zealous inspector come through.



Thomas J. Walz
Carbide Processors, Inc.

http://www.carbideprocessors.com

Good engineering starts with a Grainger Catalog.

 

[rexfire]

Sorry, I wasn't clear. I have MSDS on file for my location for the paint. We are giving it out to customers with our product for touch up. I didn't know if we are supposed to be giving an MSDS sheet to them. And occassionally we sell it to OEM customers.

 

[racookpe1978]

I have seen other companies put a sticker (or a line item in the label) saying "MSDS available on request" plus a website or 800-xxx phone number.

 

[mcgyvr]

You just have to have to be able to send it if someone requests it.
I doubt you really even need an MSDS for something like that.
Its really only for non-consumer type chemicals that employees encounter in their daily job that might be hazardous.

 

[BillPSU]

All chemicals in a plant are required to have an MSDS sheet available somewhere. At my plant we have contracted with an online service to be a repository and disseminator of the MSDS sheets for our corporation. What do I mean by all materials it includes paints, oils, grease, cleaners, coolant, adhesives, used in manufacturing our product and all other processes within the plant such as bathroom cleaners, maintenance supplies, contractors supplies anything that people can be exposed to anywhere in the plant. No material are to be brought into the plant until the EHS manager approves.

 

[mcgyvr]

According to our OSHA inspector (not saying its 100% correct) common retail products like bathroom/general cleaning products,etc.. do not require MSDS records to be maintained. The same goes for other off the shelf maintenance products like spray paints, 3in1 oil, etc..

Basically if you can buy it at your local hardware/grocery store a MSDS on file is not required.

 

[MiketheEngineer]

So why does LOWES have a whole pile of MSDS if I want one??

 

[dcasto]

Lowes has them because they have sufficient quanities on hand. A single can of wd-40 doesn't require an msds attached, 100 cans do.

 

[rexfire]

1910.1200(b)(6)(ix)

Any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended;


That is what OSHA states. So i keep MSDS for janitorial products because janitorial staff are exposed to those household products at a greater amount than what is intended for the typical consumer. So i keep them all on file.

 

[MiketheEngineer]

I can use a can of WD-40 to blow up a small house. Lets not get into ammonia, nitrogen fertilizer, etc...

I have used WD-40 to "jump" an engine into starting or shoot a potato about 100 yards!!

 

[tomwalz]

I go overboard because I am never sure how each inspector is going to interpet the law.

Once spent a half hour discussing guarding on a precision wire cutter with an inspector. Then he walked past a WW II era drop hammer that repeatedly dropped a 200# weight from 4 feet. It had zero guards. Just an open chamber. He looked at it and just walked on.

Tom

Thomas J. Walz
Carbide Processors, Inc.

http://www.carbideprocessors.com

Good engineering starts with a Grainger Catalog.