Another query re: safety data sheets Based on the contents of a MSDS of a substance we're using, it states under 'Disposal Considerations': "When a decision is made to discard this material, as received, is it classified as a hazardous waste? No." One of our Project Managers has asked for something a bit more 'substantial' to pass onto the Principal Contractor, as they have said the material IS hazardous, despite the above statement being in the MSDS. If I were to stick the MSDS under the nose of the PC and say "this is what the MSDS says", would be be sufficient to show them that the material is hazardous?

sound advice to a principal contractor would be to show them the msds and ask for their comments.I would not get involved in the technical or scentific side unless the situation becomes urgent who is the advisor to the pc?

First of all, they are not COSHH safety data sheet, as the safety data sheet is provided to meet the requirements of CHIP. Para. 13 of the COSHH ACoP actually confirms this. Secondly, the information on the safety data sheet is only valid for the product 'as supplied'. If you have used it, has its properties changed? For example, might it be contaminated with some other substance, have been oxidised, heated or otherwise changed such that the data on the safety data sheet no longer applies? Section 6-1 of the Health and Safety at Work 1974 Act refers to the information that the supplier must provide - in many cases over and above what will be provided on the safety data sheet. So in answer to the original posting, what is stated on the safety data sheet may not be relevant. I would suggest checking with the supplier, explaining what has happened to the product and then requesting the relevant information in accordance with section 6-1 of the Act. Chris

the UN/EU waste logs etc are the references / primary documents that explains what is / what is not hazardous waste & how it is disposed of so it is that area that should be consulted especially so if the PC is also managing the SWMP for the project

what are we saying here from the original question the safety data sheet as supplied is wrong because full and sufficient info as not been supplied by the seller.how long should a data sheet be and what a cop out by the supplier to say as delivered.The risk assessor as not the chance to disregard in the coshh heiarchy.do we believe data sheets or not?

Heather I agree entirely about the purpose of the safety data sheet. What I was trying also to point out was that there is a duty under section 6-1 of the Health and Safety at Work 1974 Act on the supplier to provide "adequate information about the use for which it is designed and has been tested, and about any conditions necessary to ensure that, when put to that use, it will be safe and without risks to health". I submit that this is a completely different requirement to that for the safety data sheet. I have found that many suppliers are unaware of this duty and many simply do not know how to respond when challenged on this. Chris

Bobhan. Um, well yes. It's called the COSHH Risk Assessment. It's not the supplier's duty to do that for the user. Those companies that make nice files of all their MSDS sheets, call them a "COSHH Register" and expect their employees to read, understand and follow the guidance on said sheets are riding for a huge fall. Chris - I agree and having had the experience myself of ringing suppliers to quiz them further on their rather vague MSDS sheets so that I could do a suitable and sufficient COSHH assessment myself I have found some are excellent and really helpful and some are clueless!

A preparation could be non-hazardous in the MSDS and have no risk phrases, but still be "hazardous waste". An example is base oil used in lube oil preperations:- http://catpumps.co.uk/MS...Oil%20-%20Jan%202008.pdf

To add to Jay's point, a floor cleaning detergent would normally be something that, appropriately diluted, one would put down the drain. So the safety data sheet would probably not include and advice on disposal. However, if used to clean up something hazardous, then it might need disposing of differently. Chris

The definition of "Hazardous waste" is given in the Waste Management Acts of 1996 and 2001 and specifically detailed in the Schedules of both. Theses acts are concerned primarily with Environmental Management / Safety, and are separate from the COSHH regulations / Health and Safety at Work Act. These Acts cover the transfer, storage and disposal of "hazardous waste" and are enforced by the Environment Agency. MSDS are drawn up to address both legislative requirements , Environmental Safety and Occupational Health and Safety. Wastes can still be hazardous with respect to COSHH, but are not always covered by the Waste Management Acts. PH2

I agree that I have seen some pretty 'strange' MSDS in my time, with some describing the product as non hazardous etc and then requiring a long list of protectve equipment to be worn anyway. However, for most of the time it is what we have to work with when carrying out an assessment. But I am a little confused about the very first posting (other than the fact that the title asks a question about whether an MSDS is a legal docuemnt, but the subsequent post doesn't expand on this question at all!). It says "When a decision is made to discard this material, as received, is it classified as a hazardous waste? No." i.e. NO it isn't hazardous, and I assume that the rest of the MSDS backs this up. But the end of the post then says "If I were to stick the MSDS under the nose of the PC and say "this is what the MSDS says", would be be sufficient to show them that the material is hazardous?" Is the word "not" missing towards the end of that sentence? i.e. shoukd it not read "..that the material is not hazardous"? It seems that the intial assertion that the substance isn't hazardous changes to one of it being hazardous. Apologies if I am reading it all wrong. (I have been struggling to fix a fault on this pc for 2 days and it may have got the better of me). By the way - yes I think an MSDS is a legal document By the way - it is ok to stick a hoover in your pc box isn't it?