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printreg, May, 2003
How Long MSDS Must Be Retained

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From: Debra Jacobson (djacobson@istc.illinois.edu)
Date: Wed, 21 May 2003 10:36:56

Here's a summary of a common question that we encounter with businesses. Keep in mind, you should retain at least one copy of each "modified" MSDS and "obsolete" MSDS. Obsolete meaning sheets on products no longer used. When transferring modified or obsolete MSDS out of your active files and books be sure to date the sheet to document when the product was no longer used and your employees were no longer exposed to the product.

For more information about MSDS and how they are used for environmental compliance purposes visit the Fact Sheet section of the PNEAC web site at http://www.pneac.org/sheets/
Debra Jacobson
There are two sections in OSHA's General Industry Standard that address MSDSs: 29 CFR 1910.1200 "Hazard Communication" and 29 CFR 1910.1020 "Access to employee exposure and medical records."

OSHA states at 29 CFR 1910.1200(g)(8) that the employer must ensure that the applicable MSDSs are readily accessible to employees during each work shift when the employees are in their work area(s). Thus an MSDS for a chemical must be retained for as long as that chemical is in use.

Under 29 CFR 1910.1020 (c)(5)(iii), the MSDS is considered a form of an employee exposure record. 29 CFR 1910.1020(d)(1)(ii) indicates that employee exposure records must be preserved and maintained for at least 30 years. Therefore, MSDSs must be maintained for this period of time, unless an alternate form of this information is maintained. According to 29 CFR 1910.1020(d)(1)(ii)(B) MSDSs "need not be retained for any specif ied period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least 30 years." Although this alternate form of keeping exposure records is an option, many organizations choose to maintain MSDSs for at 30 years so that they can preserve not only the required exposure information, but all of the information on the MSDS.

To access 29 CFR 1910.1020 on-line, visit http://www.access.gpo.gov/nara/cfr/cfr-retrieve.html#page1
Title: 29
Part: 1910
Section: 1020 and
Title: 29
Part: 1910
Section: 1200

Source: "Reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center

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