MSDS Compliance - when are they required?

Hey everyone!

I am a QA Manager for a food packaging manufacturer. In our process to make trays, we use glue. Of course, we have a MSDS Sheet for this glue. Recently, we added a visual system that tracks how much glue is put on a tray and in order for it to track the glue, we have to add a UV tracking solution. I asked maintenance to get a MSDS Sheet for the tracking solution. They told me that it would be a pain to get a MSDS Sheet if we don't need it and it used to be (and maybe still is) that you only have to get a MSDS Sheet if it's at a high enough quantity/ percentage of the final solution. We are SQF Level 3 but I couldn't find it anywhere in the code. Does anybody know if there is some exemption like this? I could find nothing in the code and am having challenges online!

Thanks in advance!

In my experience if it is in your facility you need an SDS for it, whether you used an once or 10k gallons, once an hour or once a year.

G

From a regulatory (OSHA) standpoint, my understanding is you only need MSDS for items you use more than standard use at home (e.g. if you use Windex to clean your office area desk once a week or so, you don't HAVE to have an MSDS from an OSH standpoint).

However, this is not a solution that would be used at home and it is possible there is a spill or some other accident - you absolutely should have an MSDS; otherwise, if there's an accident, how does your team know how to contain it and clean it up? The MSDS provides valuable chemical information that I'd imagine your maintenance team would want to have on hand in the event there are any major spills and your OSH / EHS team or HR dept would want in the event of an accident involving employee exposure to this product (splash in eyes, etc.).

On this one, I wouldn't bend. Most of this stuff is a "better safe than sorry" situation because you rarely have these situations occurring but why not be safe and not sorry? To be honest, it sounds like pure laziness to me. 

Good luck!

Oh yeah, one more thing! There should be an MSDS sent automatically with the first delivery of the chemical, at a minimum. I have experienced vendors who send MSDS with every single chemical shipment, regardless of whether it's been a day, a week, or a year since we've ordered the chemical and regardless of whether there's been a revision to the MSDS document itself. It's a way to protect the supplier from us claiming we never received one and it's a way for your company to protect itself in the event of a spill or exposure accident or some other similar situation. 

That's nice that your vendors do that for you. Unfortunately, since our vendors don't usually deal with food regs, they often aren't as concerned as we have to be. I normally have to ask for one or find it online on my own. In this case, however, it is a custom design so I would have to get them to make it. I am guessing the exemption my team was talking about was from a long time ago and has long since expired. I am glad I was not crazy for thinking we needed to have one, though! Thanks for the help!

herdy,

My experience is actually more in the field of steel manufacturing rather than food and they sent them even then.

I'm surprised your OSH/EHS/HR dept(s) didn't require that document in order to on-board the chemical in your facility.

Bottom line: protect yourself and your company and definitely get that MSDS on file.

I have a MSDS for all chemicals that is used in my factory, regardless of the amount

And this includes Fairy Liquid (an easy win if your auditing as most places use it, but few have the MSDS for it)

You need the MSDS sheet/information.  Let's face it, if you don't have something like this it will be one of the first items that your SQF Registered Auditor asks for. Always seems to work out that way! 

An MSDS is not a specific food production requirement, it is a requirement for any chemicals used in a workplace. This should not be a hardship to obtain one for your maintenance department or for the vendor to supply one.

An MSDS or SDS is required for dangerous goods or controlled products.  It is intended to provide workers and emergency personnel with procedures for handling or working with that substance in a safe manner, and includes information such as physical data (melting point, boiling point, flash point, etc.), toxicity, health effects, first aid, reactivity, storage, disposal, protective equipment, and spill-handling procedures. 

What is a controlled product?

A controlled product is any product that can be included in any of the following 6 classes:

Class A Compressed Gas

1. Class B Flammable and Combustible Material
2. Class C Oxidizing Material
3. Class D Poisonous and Infectious Material
4. Class E Corrosive Material
5. Class F Dangerously Reactive Material

​Don't forget that manufactured goods such as food packaging, are not required to have an MSDS!.

Tamale