Distributors do not have to provide the MSDSs growth mindset tree math poster to downstream customers for products that are not hazardous under the rule. OSHA is aware that many of the MSDSs provided for articles and other exempted
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A request was also received to clarify who is responsible for ensuring the MSDS is with the shipment and available in marine cargo handling operations. Ex. 11-68. growth mindset tree math poster The MSDS does not have to be “with” the shipment – it only has to be provided at the time of the first shipment. Marine cargo handling operations would generally come under the limited sealed container provisions of the rule, in which case MSDSs only have to be obtained by the employer when an employee requests it. Additionally, one commenter suggested that manufacturers be required to compile relevant MSDSs into a “unitary reference source” and periodically revise it (Ex. ). It appears that this means that manufacturers should include all MSDSs for their product line in one book, and send all of them to each customer.
Although some manufacturers have chosen this way to comply, and it would be acceptable, this alternative also results in the proliferation of many more MSDSs than the rule requires. A similar suggestion for shifting the burden is to require the chemical manufacturers to supply customers with the MSDSs directly. This is less cost – efficient, the chemical manufacturers frequently don’t even know who the customers are, and it increases the possibility that chemicals will be used without information. It does present a problem, however, for distributors. In particular, distributors of products that are considered to be articles are receiving numerous data sheets for these items, and are thus having to either distribute them or determine whether they have to be distributed. (See, e.g., testimony of the National Association of Electrical Distributors, Tr. .)