MSDS Sheets who like Mikey are in violation? Within Arms Reach!

[John Olson]

Mikey has brought attention to a very important and often overlook law. You are supposed to have MSDS sheets within arms reach at all times in your truck and be able to produce them immediately when asked by your customer or law/emergency/safety (osha) officials. They should be kept in a Binder like this one http://www.superiorcleaningsolutions.com/product-p/45989by.htm that is permanently attached to the vehicle or building/storage area.

If you are not in compliance get in compliance. Every manufacturer has MSDS sheets on their website. We are in the process of adding them to ours but each line we carry has them on their website to download or you can call me and we will email them to you.

 

[Desk Jockey]

Do yourself a favor and put each MSDS in a protector sleeve too.

They last longer and will withstand a little moisture or coffee or soda spill.

 

[Mikey P]

I called over there and got a delightful sounding Texan woman who is emailing me sheets for Stain Solve, Grout Cleaner and the Ultra Seal right now.

 

[Mikey P]

and they just arrived..

 

[mirf]

Are they in a protective sleeve yet?

 

[Desk Jockey]

 

[J Scott W]

The requirement is that the MSDS (are in the future SDS) be "easily and quickly available." Being able to quickly pull up an MSDS on-line may meet this requirement. All products sold by Interlink Supply are available on-line on the page that features the product. The OSHA or state official gets to decide if this meets the requirement. John's statement suggestion of having them in arm's reach would always meet that requirement, but sometimes your cell phone, tablet or other Internet connected device might be closer than the driver's seat in your van.

 

[doylebloss]

CFR49 does allow for "electronic" storage of SDS (MSDS) sheets. Most companies interpret this to mean accessible through a website. However, unless you carry a printer with you, it would be hard to give a copy to customer who requests it (or anyone else), unless you have access to email them the PDF file. John's idea works perfectly, but we also have customers who now store them all on the same tablet they are using to present sales videos, etc.. to the customer, and then they can access and email them to the customer. I would recommend downloading them onto your computer, tablet, or smart phone in a PDF format so you have access whether you have an internet connection or not. All the HydraMaster/CleanMaster SDS are available on our website in a PDF format.

 

[Larry Cobb]

Mikey;

I also sent you an electronic copy of the Product Data and MSDS sheet,

so you will have it in a printable format .

Also sent the industry accepted standards for Testing Protocols for testing carpet protectors.

Larry

 

[John Olson]

Thanks for sharing Scott and Doyle. Our last OSHA class it was still "within" arms reach for products being carried in your vehicle as they had to be available to hand to emergency/LEO/consumers upon request. Smart phones and PDF files are still relatively new so this change to the regulation must have been made fairly recently? last 5-6 years?

 

[rwcarpet]

Question to those in the know.......what if your chems are in a sprayer, or an inline sprayer, or quart hand bottle sprayer? (which I do use for upholstery) Do each of those have to be marked? And how would an enforcement official be able to match up each and every chem?

I get a bit nervous when I see an Ohio Motor Carrier Enforcement vehicle on the freeway with a semi pulled over. I'm sure they have the authority to pull me over and inspect.

 

[Mark Saiger]

Here are mine and reviewed on regular basis to make sure if something is added in both vans, we have the MSDS.

Butler has a spot right behind the drivers seat, or also can have right in the side door holder of the van.

 

[Lee Stockwell]

Has anyone here ever had an official ask to see them?

Personally, not 2nd or 3rd hand experience.

 

[Becker]

Sheet Sheets?

 

[Mark Saiger]

Has anyone here ever had an official ask to see them?

Personally, not 2nd or 3rd hand experience.

Have had a client ask once, so I actually just pulled it up on my smart phone, and then even emailed and text messaged the link to them faster than going to the van.

 

[ruff]

Clients a few times. Some in advance, so I emailed a link.
Never by OSHA or the likes.
Touch wood.

 

[Desk Jockey]

many times required for commercial work but never a random stop. Not even requested when stopped by the DOT for inspection.

 

[Mikey P]

Just a few customers ahead of time

 

[Shawn Abbey]

When we rolled one of our vans, chemicals went everywhere. After the driver was carted to the hospital (precautionary), I showed up on the scene and noticed the MSDS binder open on the front seat. I can only assume some official found it (within arms reach of the driver's seat), and was reviewing if any chemical was of a toxic nature.

If it wasn't for that binder, I can only guess they would have brought HAZMAT out to the scene, since they wouldn't know what they were working with.

 

[Dmreed4311]

I do not but need too

 

[John Olson]

I've been through an OSHA investigation. Scary. Had nothing to do with the company I worked for but the plant we worked at. A worker got seriously hurt and OSHA went through everything. We faced 10's of thousands of dollars in fines. Every bottle not properly labeled was $1000 fine EACH. They started out silk screened labeled but they wore off. We also had a couple of closets that didn't have all the MSDS sheets in them. Luckily since we were not the focus of the investigation we got warnings and 30 days to fix it. They came back exactly at 30 days and yes EVERYTHING was fixed. If you wonder what you need to do to be compliant you can call OSHA for a courtesy check. They will come out and go through everything and write you up for what is wrong. It wont be an" official" but you will see how well or how bad your doing. They will however come back and make sure you have fixed everything and wont give you a second chance but actually fine you so be prepared to fix EVERYTHING they tell you.

 

[Mike Draper]

Dealing with the DOT is enough to make any person hate the government.

 

[J Scott W]

John - There has not been any change to the written regulations but more of a new interruption / explanation of what qualifies as having the MSDS available.

RW - Sprayers can be unlabeled if you personally filled the sprayer from bottles that were labeled and you will be the one using the sprayer right after you fill it. Unlabeled sprayer would be a problem if the person who filled the sprayer was not the person using the product or if it was a day or more later. The idea being they might have forgotten by then what they filled the sprayer with.

I have been asked once by local fire official during a building inspection to show the MSDS file. Otherwise, just interested clients.

 

[dgardner]

I guess this is a good thread to ask the question - the only regulation I have ever been able to find that requires a driver to have something within arm's reach is 49CFR 177.817, but it says carriers transporting hazardous materials that are being shipped must have the shipping papers available within arms reach - nothing about MSDS, and it only specifies hazardous materials that are packaged for shipment.

Who can tell me what law or reg drives the requirement for MSDS within arms reach? And for chemicals not being shipped? That might not even be classified as hazardous? Is there an OSHA reg that requires this?

Now, no doubt OSHA requires MSDS and proper labeling of chemicals, but do they actually require the binder to be within arm's reach? I can't find a DOT requirement for this....

And a side question - has anyone made the transition from MSDS to SDS in the GHS format? At my day job we had to do a bunch of training for the new format.

 

[TomKing]

We keep them in a multi pocket file folder along with extra sales materials. These binders come off our trucks weekly and are update. The girls in the office call it packet tuesdays. We have 2 for each van so they are just a quick exchange and the office has the week to update and restock,
We keep them in the side door of each of our vans.
Quick easy and simple.

 

[TimM]

Who can tell me what law or reg drives the requirement for MSDS within arms reach?

172.602
http://www.gpo.gov/fdsys/pkg/CFR-2004-title49-vol2/xml/CFR-2004-title49-vol2-sec172-602.xml

 

[dgardner]

172.602
http://www.gpo.gov/fdsys/pkg/CFR-2004-title49-vol2/xml/CFR-2004-title49-vol2-sec172-602.xml

Ah, thanks! Although there is no mention of within arms reach it does say immediately accessible.

 

[J Scott W]

Ah, thanks! Although there is no mention of within arms reach it does say immediately accessible.

Thus the new interpretation to include electronic format as "immediately accessible."

We have completed the internal change to SDS Global Harmonizing here. The SDS will be released publicly gradual over the next few months.

The new SDS sheets can be pretty scary to one of our customers if they see some of the warning symbols. So, we are also completing SDS for the diluted version of all our products. If you keep the concentrate in the van or premix chems and have the concentrates back at the shop, the SDS for the diluted products is all you need to show the customer because that is all that comes into her home. Raises much fewer concerns.

 

[DangerkittyToTheRescue]

Great thread John!

I keep MSDS in all the cleaning vans in binders, a copy in the OSHA "right to know" station, a copy in electronic form, a master book and several copies to be available whenever they add another van to the fleet.

My electronic file is alphabetical by product manufactures and the PDF's can easily be mass printed by highlighting them and hitting print.

Don't laugh but I have a MSDS on the bleach and laundry soap that we use in the facility.

I even have a MSDS for the ozone machine.

It's all peace of mind against a nasty event and or a severe fine.

 

[TimM]

Don't laugh but I have a MSDS on the bleach and laundry soap that we use in the facility.

In my last real job I worked for FedEx. We even had the MSDS sheets for the White Out in the desk. They had it on EVERYTHING!