Rank: Forum user
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Help, I'm confused.
If we are a supplier / distributor and some of our products are 'dangerous' chemicals (i.e. they have flammable / corrosive etc. symbols on them) do we have to supply MSDS sheets with them?
The REACH guidance seems to imply we do - at least for the first time we supply that particular product to that particular customer. Currently, we only provide MSDS on request, as supplying an MSDS for every delivery of the 1000's of solvents, paints, chemicals etc. we supply would be a nightmare!
Anyone with similar experience......?
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Rank: Super forum user
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Phillips
As far as I am concerned the supplier/manufacturer has a duty to supply safety related information for their products if they are hazardous as per HSWA regualtion 6. - (2)
(c)to take such steps as are necessary to secure that persons supplied by that person with the substance are provided with adequate information about any risks to health or safety to which the inherent properties of the substance may give rise, about the results of any relevant tests which have been carried out on or in connection with the substance and about any conditions necessary to ensure that the substance will be safe and without risks to health at all such times as are mentioned in paragraph (a) above and when the substance is being disposed of; and
(d)to take such steps as are necessary to secure, so far as is reasonably practicable, that persons so supplied are provided with all such revisions of information provided to them by virtue of the preceding paragraph as are necessary by reason of its becoming known that anything gives rise to a serious risk to health or safety.]
Have you considered providing MSDS via your website where clients can dowload MSDS in PDF form? This may be a more practical option, at least for the less hazardous substances.
Ray
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Rank: Super forum user
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I thought there was still an obligation to pass information down the supply chain under REACH; therefore, only supplying MSDSs on request is not enough.
LB
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Rank: Super forum user
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LB
There will be an obligation to provide what are termed Exposure Scenarios under REACH, but as I understand this Regulation, not until a substance is registered. Once the substance is registered, then the registrant will have to supply an Exposure Scenario for each of the registered uses. Note, this applies only to substances, not preparations. A downstream user who is a formulator may, if he elects, produce a new Exposure Scenario for his product, or he may simply take the Exposure Scenarios for the individual constituents and attach these to his safety data sheet for his product. So if you purchase a product that contains, say, 10 ingredients, you could, in theory, receive one safety data sheet attached to which will be 10 Exposure Scenarios for the individual constituents relevant for the particular use for which the product is intended. What happens when the Exposure Scenarios from the different substance registrants disagree is not clear.
Of course, if your use has not been included in any of the original substance registrations, then the use of a product containing that substance for that unregistered use will be illegal.
Confused? So are the rest of us!!!
Chris
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Rank: Super forum user
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Rank: Forum user
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.....so if there is a requirement to pass MSDS downstream (not on request via post or websites) how does this work in practice. Does anyone have any practical experience of this in a large warehouse / distribution setting?
We have a 10 acre warehouse full of various chemicals & substances and I'm not sure how we could supply an MSDS with each delivery.
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Rank: Super forum user
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do you supply a delievery note for invoicing or even QA purposes with every delievery?
Its a silly Q? I know but its the same principal as a judge would say that if you can do it for one area [a none legal requirement] then you can do it for another area [where there is a legal requirement]
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Rank: Super forum user
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The SDS has to reach your customer. It doesn't have to physically accompany the delivery. The relevant SDS could be e-mailed to your customer on receipt of their order. Thereafter, the distribution of that info. within the customer's organisation can be left to them to manage effectively?
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Rank: Super forum user
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The SDS only has to be supplied on the initial shipment, and thereafter only if changes have taken place.
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