Q: Do our jobsites need a copy of the MSDS? I thought that we as a company needed 1, as long as we produce the binders within 24 hours.
A: There is nothing in the Hazard Communication standard that allows an employer 24 hours to produce an MSDS. I have highlighted the key words: “readily accessible” and “immediately” as indicators that the best safety practice would include having an MSDS for each solid, liquid, and gas chemical readily available at each worksite. Also notice that it is the employers duty to provide an MSDS to OSHA if requested to do so (see 1910.1200 (g) (11) below.
1910.1200(g)(8)
1910.1200(g)(8) The employer shall maintain in the workplace copies of the required material safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access, microfiche, and other alternatives to maintaining paper copies of the material safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)
1910.1200(g)(9) Where employees must travel between workplaces during a work shift, i.e., their work is carried out at more than one geographical location, the material safety data sheets may be kept at the primary workplace facility. In this situation, the employer shall ensure that employees can immediately obtain the required information in an emergency.
1910.1200(g)(10) Material safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in in their work area(s).
1910.1200(g)(11) Material safety data sheets shall also be made readily available, upon request, to designated representatives and to the Assistant Secretary, in accordance with the requirements of 29 CFR 1910.1020(e). The Director shall also be given access to material safety data sheets in the same manner.
