The Occupational Safety and Health Administration (OSHA) modified the rules regarding SDS on June 1, 2015. The new regulations that went into effect required all chemical suppliers to provide GHS-compliant labeling and Safety Data Sheets (SDS) on all chemical products.
The first phase of the MSDS to SDS transition went into effect in May 2012. By December 2013, companies were required to train all employees on the formatting and labeling changes. As a manufacturer, June 1, 2015, is the date our MSDS sheets were to be updated if we sold products that fell into the hazardous category. However, VMS does not publish or offer MSDS/SDS related to our aluminum and stainless manufactured products for this main reason.
In 1985, OSHA’s “Right-to-Know” law went into effect, establishing national standards for the proper identification and labeling of “hazardous materials” per section 29 CFR 1910.1200 of that law. Material Safety Data Sheets (MSDS) thus became the primary mechanism for the recording and delivery of that information. However, this law also defines and limits the materials to which these requirements apply and specifically exempts materials therein defined as “articles.”
Aluminum jacketing, stainless steel jacketing, aluminum and stainless steel sheet products, and related metal accessories are considered “articles” under the law and therefore do not require MSDS. “Articles” are defined as manufactured items that are formed to a specific shape or design, have end-use functions emanating from their shape or design, and do not result in exposure to any hazardous chemical under normal end-use or in conjunction with normal installation processes.