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Posted by / 01-Aug-2017 06:51

Beyond use dating for compounded pharmaceuticals

The Haz Com standard does not specify a minimum amount, for good reason.

Some chemicals are exceedingly dangerous in even milligram quantities while others are not.

These state plans are monitored by federal OSHA and must meet the federal standards. There are currently 26 state plan states in addition to Puerto Rico and the US Virgin Islands.

See more information on how state plans work and which ones have standards that differ from federal OSHA's as well as a state plan FAQ.

If a material is hazardous and not listed below, then it generally requires an SDS: An "article" means a manufactured item: (1) which is formed to a specific shape or design during manufacture (2) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (3) which does not release, or otherwise result in exposure to, a hazardous chemical under normal conditions of use.

Any product which meets the definition of an "article," would be exempt from the requirements of the Standard.

For a history of Safety Data Sheets (dating back to the ancient Egyptians! OSHA began requiring MSDS's for hazardous materials effective May 26, 1986 under .1200, the OSHA Hazard Communication Standard.

Quoting federal OSHA: "States with approved plans must adopt standards identical or comparable to Federal standards .For additional information see this 1993 OSHA interpretation as well as this 2005 interpretation titled "Requirement to disclose all chemicals having scientific evidence that they pose a health risk regardless of concentrations present in the product on the MSDS." OSHA requires SDS's ONLY for materials that a) meet OSHA's definition of hazardous and b) are "known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency".THE FOLLOWING ITEMS **MAY** BE EXEMPTED Hazard Communication Standard .1200 (OSHA wording is in green).Risk is a function of the inherent hazard and level of exposure.A substance either is or is not a hazardous chemical; the HCS definition cannot be read to indicate that a substance could be a hazardous chemical in some concentrations but not in others." To summarize, an SDS is required in almost every case unless there is essentially no way that the amount of material could cause harm.

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Remember, OSHA does does not define something as hazardous in a particular amount.

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