Real Talk: Do we need to have an SDS from each manufacturer of the same item?

Question: If we have a drug say that is made by Zoetis and the next time it comes in it is from Novartis and the next someone else, do we need to have an SDS sheet for each manufacturer, or is one generic SDS for the item sufficient?

Answer:

The short answer is - yes, one SDS is sufficient. You can do this provided it is the same formulation, but you take on additional responsibility. It is simpler to maintain an SDS from each manufacturer.

Here's the long answer:

You can maintain a single SDS to convey the hazard information for chemical products of the same formulation that are supplied by different manufacturers. If you do this, you become responsible for ensuring the following:

1. First, [the employer] must ensure that the specific identity on the SDS can be cross referenced to the corresponding label of the hazardous chemical containers.
2. Second, the employer must ensure that employees are informed during the hazard communication training of this practice of using one MSDS as representative of all vendors, otherwise it could lead to confusion.
3. Third, the MSDS [the employer] select[s] must have complete and accurate information as required by section (g)(3) of the HCS.
4. And finally, the standard requires that the MSDS contain the name, address and telephone number of the party who prepares or distributes the MSDS.
   1. The party listed must be able to provide additional information on the hazardous chemicals or clarification of the information on the MSDS, as well as, additional emergency procedures, if necessary, in lieu of the actual manufacturer.
   2. A chemical manufacturer, importer or distributor may not wish to and is not required to act as the responsible party for a chemical that they did not produce."

Basically, the standard allows substitution of one MSDS for others of similar formulations, but the employer then assumes an increased level of responsibility as discussed herein.

Reference

1. Letter of interpretation from OSHA - https://www.osha.gov/laws-regs/standardinterpretations/2004-09-08-0 

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