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Ask the Experts
Material Safety Data Sheets
I was informed that we are supposed to be archiving obsolete MSDS pages for 30 years. Is this true?
C.B., submitted online
Maintaining obsolete material safety data sheets (MSDS), those associated with hazardous materials no longer in one's inventory, is one means of complying with OSHA's “Access to employee exposure and medical records” regulation found in 29 CFR Part 1910.1020. Archived MSDSs are considered employee exposure records in that they represent a history of hazardous materials usage and provide data indicating that the materials posed a hazard to human health. When employed as worker exposure records, MSDSs must be maintained for “at least 30 years.” Thereafter, an employer must notify the director of NIOSH in writing of the impending disposal of preserved MSDSs at least three months prior to their disposal.
As an alternative, an employer may discard obsolete MSDSs if a record is created and maintained for the 30-year retention period that includes the following information:
- The identity of the hazardous material, including ingredient chemical names if available.
- Information on where and when the hazardous material was used.
Obviously, this approach provides substantially more useful information than does a collection of MSDSs. The acceptability of these two different approaches to satisfy the requirements of this regulation was quite purposeful, resulting from a desire to provide employees with access to meaningful exposure records and a simultaneous desire to minimize employer objections to this standard during the rulemaking process. In either case, employers have an annual obligation to inform employees of the existence, location and availability of relevant employee exposure records, regardless of their format.
Michael Beckel
3E Co.
An employer may discard obsolete MSDSs if a record is created and maintained for the 30-year retention period that identifies the material and designates where and when it was used.
Safety Signage
In what OSHA regulations will one find references to specific signage requirements?
F.H., Seattle
OSHA's standards include specifications, designs, and applications, as well as instructions on how to use header-style accident prevention signs, which are those that feature the words “Danger,” “Warning,” “Caution,” “Notice.” These signs are intended to indicate the potential, type and degree of the hazard that may lead to accidental injury or property damage. Accident prevention signs, or health and safety signs as they are commonly called, are intended to convey a clear and easily understood message pertaining to specific hazards.
One of the most important OSHA standards pertaining to safety signage and header severity can be found in 29 CFR Part 1910.145.
Other notable OSHA standards include the following:
- 29 CFR Part 1910.37, Means of Egress (exits and evacuations)
- 29 CFR Part 1910.253 (b) (1) (ii), Compressed Gas Cylinder Marking
- 29 CFR 1910.146 (c) (2), Permit Required Confined Space
- 29 CFR Part 1910.335 (b) (1), Safety Marking for Electrical Hazards
- 29 CFR Part 1910.1450 Appendix A (D) (8), Safety Marking for Safety Showers, Eyewash Stations and More
- 29 CFR Part 1910.147, Lockout/Tagout
- 29 CFR Part 1910.1200 (a) (1), Hazardous Communication Marking
- 29 CFR Part 1910.1096 (e) - (i), Radiation Area Marking
- 29 CFR Part 1910.1450 Appendix A (D) (8) (c), Safe Food Consumption and Storage
- 29 CFR Part 1910.157, Marking of Portable Fire Extinguishers
It is important to note that there are dozens of other standards that include information on required safety signage identification. Each standard must be researched thoroughly to ensure a complete understanding of its intended purpose. CM
Brad Montgomery
Accuform Signs
Our Expert Panel
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