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#1 ctzinck

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Posted 02 August 2016 - 05:56 PM

I have a couple customers who are asking for SDS Sheets for the packaging materials we produce for them, The structure would be similar to: Flexible Film- Ink -Adhesive (or Poly Extrusion) - Flexible Film.

 

In the pst we have always supplied the individual SDS sheets that we got from our suppliers for the individual components but how to I go about merging all that information into a single SDS sheet.

 

If there are two customers asking for this I can most likely count on others following suit....

 

Thanks for any help any one can provide 



#2 ncorliss

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Posted 02 August 2016 - 06:02 PM

We do injection molding of products. When I've received statements requests on SDS I've provided them a statement with this said verbiage:

 

"When delivered to our customers, the materials are molded and assembled into the final processed, solid form. In this final processed form, the products are not considered hazardous per the Occupational Safety and Health Administration (OSHA), the Regulation on Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH), Regulation for Classification, Labeling, and Packaging (CLP) and the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

 

According to regulations in OSHA 29 CFR1910.1200, Reach 1907/2006EC, CLP 1272/2008/EC, and the guidelines within GHS, an SDS is not required to accompany these products.

 

Our company confirms the food grade products pose no identified hazardous material risks from direct physical contact and no special handling precautions for hazardous material is required."

 

I would also include a regulatory statement which listed out the confirmed 21 CFR codes along with food types and conditions of use.



#3 Charles.C

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Posted 02 August 2016 - 08:04 PM

I thought they were called MSDS sheets.

 

Obsolete ? or perhaps a Packaging/US innovation ?


Kind Regards,

 

Charles.C


#4 InventoSteve

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Posted 02 August 2016 - 08:52 PM

I thought they were called MSDS sheets.

 

Obsolete ? or perhaps a Packaging/US innovation ?

 

MSDS transitioned to SDS last year to bring the US standards inline with the rest of the world (Wish we could do that with Metric).  Don't feel bad though, it's shocking how many companies were caught unaware. 

https://www.osha.gov...s/OSHA3514.html

 

Here are the major changes according to OSHA:

https://www.osha.gov/dsg/hazcom/



#5 mgourley

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Posted 02 August 2016 - 09:56 PM

It's now (has been) the Globally Harmonized System.

 

:yeahrite: SMH

 

Marshall



#6 Charles.C

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Posted 02 August 2016 - 10:46 PM

Hi Steve/Marshall,

 

Thks for the above.

 

I deduce I am 4 years out-of-date although probably not alone as per the appended comments within link below.

 

I also deduce there are some consequences from the change (or at least were anticipated in 2012)  -

 

https://www.msdsonli...rom-msds-to-sds

 

PS - @ctzinc - Sorry for slightly diverting yr OP.


Kind Regards,

 

Charles.C


#7 Karenconstable

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Posted 08 August 2016 - 07:41 AM

I see quite a lot of SDSs in my job and the original post looks like a case of the customers really wanting a product specification with compositional information.  Since these can be rare for multi-layer packaging materials, customers sometimes request SDS as a 'default'.

 

As Norcliss rightly suggests, an SDS is supposed to be all about hazards from the material, and the content he/she suggested meets the regulatory requirements for SDSs, but won't meet the needs of a customer who really wants to know what is IN the finished product and who might be requesting this information so they can create raw material specifications for their food safety management systems. 

 

I think this type of request will become more common for food packaging, so I recommend you make/amend a finished product specification which has a basic description of the finished product (eg. three-layer laminated flexible film) and its intended use, plus specific information about the materials of composition of each layer and their grades or level of purity if relevant. You could also include characteristics of the final film (all layers) such as thickness and suitability for various sealing methods, packaging machinery types, etc. Definitely include the CFR21 compliance information mentioned by Norcliss if the material is intended to be used for food packaging in the USA.  One benefit of this document is that you will not have to reveal your suppliers, as you do when providing SDSs for individual components.



#8 ncorliss

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Posted 08 August 2016 - 01:49 PM

To add to Karen's comment. My regulatory statement includes a breakdown listing the finished product's component, material used in component, and applicable CFR regulation. I recommend having your engineering, sales, and legal team review any statements you implement to ensure you don't give away and proprietary information.



#9 SeanMartinez

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Posted 03 January 2017 - 02:34 AM

OSHA has revised its MSDS requirements to conform to the UN introduced Globally Harmonized System of Classification and Labelling of Chemicals generally known as GHS and compliance to HazCom 2012 is mandated by June 2016. It is expected of chemical manufacturers and dealers to upgrade their Material Safety Data Sheets to GHS safety data sheets.






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