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Posted By Owen Needles
Apologies for being as thick as a whale omlette but i'm struggling to find some info. I have been told on good authority that you should check any MSDS's you are using every 12 months with the supplier/manufacturer. You should also keep a written record of this communication (e-mail, letter , fax) to prove you have been checking that you are working to the latest version.
I've been trying to find which regulation states this but can not find it in either COSHH or CHIP. All i can find is that the supplier should make every effort to inform you of changes.
Is what i've been told legally correct or is it advice (best practice) to cover yourself/company.
Any help would be appreciated
Regards
Owen
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Posted By Adrian Watson
Best advice.
Regards Adrian Watson
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Posted By Descarte
A black adder fan here me thinks,
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Posted By garyh
The responsibility is on the supplier to ensure that customers are sent copies of the SDS if any significant change occurs.
You can't really check yourself - the day after you check things could change.
However, the main reason for change would be if legislation changed eg CHIP, EH40, or classification changed (approved supply list), this sort of thing. You might need to ask the question but then again, the supplier should do that.
I do not believe there is any obligation to check on SDS for materials supplied to you.
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Posted By anon1234
I tend to agree with garyh but I think you should have a system in place to ensure that you have a MSDS for all the materials you use and from the correct supplier. The key thing is that the information gets to the people at the sharp end as I'm sure you appreciate. Under COSHH you should be regularly reviewing your COSHH assessments so why not tie in a check on the current validity of the MSDS when you are reviewing the assessments.
This together with the requirement on suppliers to endeavour to update such information to you should cover the bases so far as reasonably practicable.
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Posted By AJM
I myself went through this process at a previous company. I found it a very worthwhile exercise, especially being as some where 20 years out of date.
As part of my COSHH project i audited every single one, some that were non hazardous were suddenly hazardous. I even went into the detail of questioning the suppliers because i found a couple with EH 40 chems in and exposure limits they had not even mentioned.
They were even thanking me for pointing stuff out and getting them to change there own sheet. So that certainly leaves a question as to if some of these suppliers are taking it seriously too.
When all said and done you have to check your COSHH assessment every year or two, and your biggest reference is the MSDS sheeet, so in my opinion you should be checking it as part of that process as a matter of course.
Alan.
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Posted By garyh
Having done many COSHH assessments, and authored and managed MSDS production, I have never routinely queried supplied MSDS's unless something " stands out".
You have to take it that the supplier is compliant - they are the expert on their products! And, what if you were supplied with hunfreds of MSDS's? Would you be able to follow them all up?
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Posted By John Murgatroyd
Having checked one msds with the techicians who did the testing at a univ I can categorically state that in both my opinion, at the time, and also the techs opinion, the msds did not provide the necessary correct information to assess the risk from the product in a specific case. ie: the fume risk from welding on metal coated with the material.
The msds did not state that the fume measurements obtained were as a result of a paint layer 10 microns thick being on the test material. The coating was applied to the material being worked-on in a thickness of over 150 microns.....the fumes were over 15 times the stated amount. Further, due to the test thickness being so thin, the paint was being burnt more efficiently, so the fumes on the metal being worked-on contained higher levels of hyrocarbons anyway.
All this as a result of the msds not stating the method and thickness of the test material.
And it isn't the only one that was found to be grossly inaccurate.
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Posted By Chris Packham
Just to put a complete spanner in the works, caution is required when using safety data sheets for a COSHH assessment!
In a poster at the major skin conference in Stockholm last year some dermatologists revealed that a study of SDS showed as many as 42% were inaccurate regarding skin hazards. There are several other studies that show a high percentage of inaccurate and potentially misleading SDS.
Furthermore, remember that SDS are generally written to comply with CHIP. CHIP is for packaging and labelling for supply. What you need for COSHH is data for use. The two are not necessarily the same. I have had situations where significant (and reportable) skin problems have occurred because of this.
In fact, if you refer to the COSHH ACoP, it specifically mentions that a SDS written for CHIP may not be sufficient for COSHH!
What is required of the supplier is information to enable the safe USE of the product supplied. This is laid down in the original Health and Safety at Work Act, but many suppliers do not appear to be aware of this. They are often surprised when I point out to them that the information they have provided may not meet their legal responsibilities.
I have a more comprehensive document on this. If anyone would like me to e-mail them a copy, then I suggest that they contact me direct.
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