In terms of Regulation 9A (1) of the Hazardous Chemical Substances Regulations every manufacturer, importer or trader of any chemical substance for use at work shall provide the person receiving such substance with a material safety data sheet (MSDS). This MSDS shall conform to certain minimum standards (ISO 11014) and it must therefore be the ’16 point’ MSDS.
Every employer shall have a file with all current MSDS’s that are in use and this file must be available to all employees working with the products as well as to the Occupational Health Practitioners and the Fire Department in the event of a fire / evacuation.
When we do Hazardous Chemical Risk Assessments on companies we regularly find the following mistakes:
a. The MSDS’s are illegible (Copy of a copy of a copy . . . )
b. The MSDS’s are outdated copies (i.e. not the current format)
c. The MSDS’s are technical bulletin (that is not a MSDS)
d. The MSDS is no longer in use
e. There are more than one copy of the same MSDS in the file (have seen up to 6 of the same in one file)
Let us look at each of these mistakes:
An MSDS can be a very good selling point for a company. I would rather buy a product from a company that gives me a neat copy than a company that gives me a ‘dog’s breakfast’! Why fax a copy if you can e-mail an ‘original’ or even better drop one off and have a personal contact with your client. If the MSDS is illegible, what good is it? I have recently seen MSDS’s that I could not with the best will in the world encipher.
I regularly come across the outdated 1990 odd MSDS’s. They are outdated and are no longer valid. They also do not have the required information that is needed in an emergency. A MSDS may not be older than 3 years and that is why it has a date of issue (should have).
There is a major difference between a Technical bulletin and a MSDS. The bulletin looks at the technical aspects of the product – application, specifications etc., while a MSDS looks at the health, safety and environmental aspect, including packaging, and transport.
Files that are cluttered with additional copies or with copies no longer in use are an annoyance! Imagine the fire department has to put out a fire and it asks for the MSDS file. In this emergency they have to wade through so much trash that they give up – and that could be at the expense of a life. The file should be updated on a regular basis and only contain all the current MSDS’s.
For record purposes you may keep old MSDS’s but in a separate file / filing cabinet.
Remember a MSDS is a legal requirement, it is a window to the supplier and it is a document that may hold vital information during a mishap. Do not purchase from a supplier who does not have the decency to give you (free of charge) a proper, current MSDS. As a consumer, please ensure that your MSDS file is current; all are updated and legible copies. On the “presentation” side is a copy of the current MSDS.
Written by Frans Wilbrink of Wilbrink & Associates, tel. 031 – 266 9035