Summary for msds requirements Discussion
Chrome plating compliance issues often come down to whether common shop products are exempt under OSHA’s HAZCOM rule. In this thread, Jimmy James Canfield asks if three brands of auto wax, duct tape adhesive, and household-style janitorial cleaners all need separate MSDSs. The answerer advises starting with the applicability section of 29 CFR 1910.1200 and notes that consumer-product exemptions may apply to the items mentioned. He also points out that many shops collect MSDS sheets for everything “just to be safe,” but that is not actually required by OSHA. The practical takeaway is to check the standard carefully rather than assuming every off-the-shelf product needs its own sheet, especially when the products are used in a manner consistent with normal consumer use.
Hello and thanks to those reading this inquiry.
I have just been asked to head up a compliance and safety position.
After reviewing the current MSDS book the owner has I have found several items that needed a MSDS. This was no problem. However now it’s on to the things we tend to overlook.
For instance they use about 3 different brands of auto wax for final cleaning and protection of the newly chrome plated parts. Would there need to be 3 separate MSDS for these waxes?
I have also been notified that Duct tape adhesive contains about 14 chemicals that require MSDS’s. Is this true?
The final inquiry is on the Janitorial chemicals that are actually home based toilet bowl cleaners, glass and mirror cleaner, and floor wash. Would these also require an MSDS?
Thanks again.
Jimmy
James Canfield
Safety and Compliance – New Castle, Indiana
A. Hello James. Start by reading the applicability section of the HAZCOM standard (29 CFR 1910.1200). There are some exemptions for consumer products that may apply to the products that you mentioned. Many shops just get MSDS sheets for everything imaginable just to be safe, but that is really not required by OSHA. Good luck.
Jon Barrows, MSF, EHSSC
Independence MO
July 15, 2010
A. The nice thing about having several thick notebooks of MSDS’s, the inspectors do not have much of a clue as to which ones to look at.
James Watts
– Navarre, Florida
July 16, 2010
A. James, Jon is right but one caveat- non consumer quantities of consumer materials require an MSDS. Also a clarification: you do not need an MSDS for each chemical contained in a product what you need is an MSDS for the product itself. Contact the manufacturer, however you can often find the MSDS online by using a search engine.
If you are buying the supplies and custodial products from an industrial supply type company they are very familiar with you type of inquiry
Gene Packman
– Great Neck, New York
July 19, 2010