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Posted By Mike Foulds
Hi just need a heads up, I have a client who we distribute products for (big household name)they are tell me that they do not need to supply any MDSD sheets for their products.
They have gone to lengths to produce a Power Point presentaion quoting EU 1272/2008 and amendments 67/548/EEC and 1999/45/EC.
These basically say:
The regulations do not apply to substances or mixtures in a finished state that are intented for use by the final user.including medicines, animal health, cosmetics, medical instruments and food stuffs.
Thats fine as a memeber of the public does not need this info but what about my distribution centre where we have bulk quantities of finished product, what if there is a spill, a fire, environmental contamination?
Most if not all our other clients play ball and supply MSDS sheets so I have not come across this issuer before.
I have glanced through the regulations but they are sizable and I just have not got the time to sit, read and understand them at this stage.(its heavy stuff not like a good old H&S Reg.)
Can anyone offer advice on the legal standing of supplying MSDS?
Thanks
Mike
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Posted By Paul Leadbetter
Mike
What about section 6 of HASAWA?
Paul
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Posted By Jay Joshi
Most of these products would have the ingredients listed and sometimes the proportions.
I presume that this could be done if it is made a part of the contract for the client to provide specific minimum information??
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Posted By Ron Hunter
On the face of it, it is quite probable that none of what you describe is likely to be hazardous for supply = no MSDS.
Do you really have "bulk" storage, or just a lot of final containers/packs in one place?
Yes, many if not most suppliers "play ball". This approach has been the bane of H&S for many years now, with a 'knee jerk' reaction of "Have MSDS = must produce COSHH Assessment" for harmless products!
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Posted By Mike Foulds
Thanks for your responses, I can now see the wood much more clearly
Mike
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Posted By TonyB
Ron,
Just a quite note. Although most of what you describe is totally correct, I do have one issue. Namely, medicines. Medicines are often at least harmful - they are designed to have an impact on the human body. Therefore, COSHH assessment may very well be justified.
All the best,
TonyB
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Posted By Ron Hunter
I don't necessarily disagree with you Tony,indeed the same could be said for the animal medicines, however it seems to me from what is described here that there is a greater likelihood of slipping on the contents or cutting myself on the fragments of a dropped bottle of (e.g.) cough syrup.
What I am advising against is a temptation to conduct COSHH Assessments, rather look at the potential for spillages/breakages, how to clean that up, and how to dispose of it properly - more storage & transport from HASAWA, as opposed to COSHH. There doesn't look to me to be any potential for "exposure" in this transport and distribution undertaking?
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Posted By Paul Leadbetter
But, in the absence of any safety data, whether on an MSDS or not, how will people know what precautions to take when cleaning up?
Paul
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Posted By Mike Foulds
This has been my issue with the supplier all along, how do we know if the product is harmfull or not?
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Posted By Ron Hunter
There has to be a route for exposure. I'm suggesting that in storage and distribution, this isn't an issue - unless some foolish employee decides to sample your wares!
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Posted By Jonno Johnson
...and don't forget drugs that are consumed by patients, but could harm the person administering them, such as cytotoxic drugs. This is a popular tac taken by the (old)Healthcare Commission (now CQC) when visiting hospitals.
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Posted By Jay Joshi
You may want to look at the transportation class/hazards under the Carriage Regulations.
Medicines, both in liquid and sold form, if toxic are inluded in the ADR list.
I wonder what transportation hazard information is provided, unless it is done under the guise of limited quanity exemptions, which is most likely!
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Posted By Jay Joshi
I presume that rather than a full blown COSHH assessment, you main concern may be how to deal with a spillage in your warehouse?
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