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kenuk1  
#1 Posted : 15 August 2013 09:06:29(UTC)
Rank: Forum user
kenuk1

Hi all, We manufacture a carbon product that we sell solely to steel manufacturers, for years we have supplied MSDS sheets that were translated from our parent company, by whom I have no idea. We produce our product by mixing carbon/graphite with various, cements, silicas, zirconias and phenolic resins, obviously controls are in place for all the materials we use and everything is COSHH assessed for internal safety regulations. The mixed material form a "batch of our material" for which we dont have an MSDS for, and this is my first query, as our "mixed" batch is a collection of ingredients, should we not have a requirement to produce our own internal MSDS based on those ingredients, and carry out COSHH based on that MSDS? If so, where would I start with this, would it be a case of sending a sample of our "mix" to a lab for analysis to allow the production of the MSDS? Once the powders are mixed, they are bonded with the resin and form a hard/solid product which is fired to basically get rid of any volatiles. Customers are asking for the MSDS of our "mixed" material, which has no bearing on their safety as its a solid when it arrives to their site as a product, the product we supply does not produce a dust unless they are cutting it, which is not normal, the product is simply used in molten steel and disposed of. Does anyone have any advice on what we should be providing the customer, I feel MSDS is powder, liquid etc as opposed to a solid that doesn't pose a risk as it is, obviously hit it with a hammer, it goes in your eye... Any advice greatly appreciated, I think customers are maybe using this method to find out exactly what goes into the product, which is a highly guarded secret between competitors, and unfortunately, I can't get hold of competitor information to see how they are managing.
teh_boy  
#2 Posted : 15 August 2013 09:20:19(UTC)
Rank: Super forum user
teh_boy

A very quick very rushed reply... but May be simple, maybe not :) How much do you make? If it's over 1 tonne you may have higher requirements under REACH : http://www.hse.gov.uk/reach/ As it stands - you should obtain SDS's for all substances supplied to you, and use these to carry out a CoSHH assessment (as it's what you do and what you produce in the process that matters) next you must supply your customers with an SDS on the product you supply - this must be done for hazardous substances and as you say, for an article there is no requirement. there may be a requirement if the solid provides a bioavailiable toxin though. It is up to you as the manufacturer to test the product and ensure the SDS accurately reflects hazards - this all starts getting complex now and I would seek expert advice. As for SDS of the mix - yes please then I can make my own! Cynical maybe, but I don't see how it's relevant to your customer?
kenuk1  
#3 Posted : 15 August 2013 09:32:53(UTC)
Rank: Forum user
kenuk1

You're on my wavelength I feel, I've looked at REACH and it is classed as an article only if the shape is more important that the composition, well, they're equally important I guess... Like you say, maybe simple, maybe not....haha
teh_boy  
#4 Posted : 15 August 2013 09:49:11(UTC)
Rank: Super forum user
teh_boy

PM me if you want to chat about it - I'm in the office today, a rare treat :)
kenuk1  
#5 Posted : 15 August 2013 10:56:00(UTC)
Rank: Forum user
kenuk1

Thanks for the offer, I've got the list of SVHC's for Articles in REACH off ECHA this morning and, going through them, there's one or three that may apply to our final product, for sure they are in our batch mix, but after going through a drying and firing process, neither myself or anyone else within the group can answer which CAS numbers may exist in the final article and at what percentage. I think I'll keep this thread up to date if thats ok, simply because what Im doing I feel others will need too if they haven't already, my next step is to get in touch with Intertek to go about testing our final product to determine the material types, if they have SVHC's then I guess we go from there, and this would, I guess, allow me to produce an accurate MSDS aswell. Thanks for the offer by PM, lets see how it goes with this process and I'd be grateful to chat further...
teh_boy  
#6 Posted : 15 August 2013 11:02:45(UTC)
Rank: Super forum user
teh_boy

Sounds like you've got it under control anyway! Good luck...
chris.packham  
#7 Posted : 15 August 2013 11:22:12(UTC)
Rank: Super forum user
chris.packham

You have PM Chris
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