MSDS Required for Plated Parts?
We are a zinc plating job shop. Some of our customers are requesting MSDS's for our product. This includes zinc and chromate. Is there any industry standard for this?Jeff G
- Punxsutawney, Pennsylvania, USA
Ed. note: See also letter 5859 which is very similar.
This is how I responded to our customer's request for MSDS on zinc & chromate coatings.
"I have investigated your request for Material Safety Data Sheets (MSDS) for materials applied to your parts. Please find enclosed MSDSs for materials including oil, wax and zinc metal that ORP employees may come in contact with as a result of handling rods processed by MMF.
"I have contacted several of our chemical suppliers and have determined that no MSDSs for dried chromate conversion coatings or zinc phosphate coatings are readily available. Also, according to 29 CFR 1910.1200 (regarding Hazard Communication) articles are exempt from the standard to maintain MSDSs.
An article is defined in the standard as:
"A manufactured item (i) which is formed to a specific shape or design during manufacture; (ii) which has end use functions(s) dependent in whole or in part upon its shape or design during end use; and (iii) which does not release, or otherwise result in exposure to, a hazardous chemical, under normal conditions of use.'
"An example of the difference between an affected chemical and an article might be that if you purchase turpentine at a hardware store, you are provided an MSDS. If you purchase a hammer with a painted handle (or zinc plated nuts & bolts), no MSDS for the coating is required.
"As a result of numerous discussions with MMF's chemical suppliers and other sources (including the editor of "Products Finishing" Magazine), I have determined that I am unable to provide MSDS's for the coatings as you requested. Further, I have found no evidence of any governmental requirement for manufacturers to maintain MSDS's for finished coatings which are adherent to articles they manufacture.
"Please let me know if I can be of further assistance in this matter."Craig S
- Cincinnati Ohio USA
I took quite a different approach in a talk I gave on ISO14000 issues at the AESF Empire State Regional last week.
In it, I said that, 5 years ago, Cadillac in Canada was so concerned about exposure of skin to chromated parts, that they started to make their workers wear gloves during handling.
So, even if no MSDS are available, I feel that someone (e.g. AESF, MAMF, NAMF, MFSA) should get the information on this issue, and come up with something that will protect the jobshops from potential liability, not to mention protecting people from exposure to hexchrome from the "chem film".
The larger jobshops who do this on their own will be doing themselves a favor. The smaller jobshops should gang together to find the information.
Falls Township, Pennsylvania
If we were talking about finished articles that were chrome plated or gold plated, or anodized, or powder coated, I would agree with Craig. Because, as far as anyone knows, there is simply no reason for concern about exposure to such parts or handling of them, so let's not fill the world with meaningless paper if the law doesn't require it.
But I have to agree with Tom in the case of chromated parts. We may not yet have hard & fast proof that chromated parts are hazardous to handle, but many of us certainly have our suspicions. And in such a case the "no controlling legal authority" approach is unlikely to be the best approach :-)
Ted Mooney, P.E.
Pine Beach, New Jersey
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