The Hazard Communication Standard “requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs), formerly Material Safety Data Sheets (MSDS), for each hazardous chemical to downstream users to communicate information on these hazards.”
Whereas Safety Data Sheets for many lubricants are readily available from lubricant manufacturers and distributors, the Petroleum Quality Institute of America (PQIA) receives a notable number of inquiries from companies asking PQIA for Safety Data Sheets for motor oils seen on our website. In some cases, they contact PQIA because they say there is no contact information on the lubricant labels they have at their worksite. And since the product was on PQIA’s website as one we tested, the hope is that PQIA can provide either the SDS or information as to where they can obtain it.
Although PQIA makes every effort to assist, in some cases, we simply cannot since information about the responsible party is not on the product label and information about the product cannot be discovered by a reasonable level of online research. This should not be the case and it is in fact unlawful to manufacture or distribute such products without identifying the responsible party on the label (see Labeling – Responsible Party).
In addition to these situations, however, some say that where the name of the company that manufactures or distributes the product is on the label, they were unable to make contact with anyone within the organization able or willing to provide an SDS.
Where many lubricant manufacturers provide ready access to Safety Data Sheets on their websites, based on the number of inquiries received by PQIA over the past few months, now may be a good time for lubricant manufacturers and distributors to examine the process they have in place to provide access to Safety Data Sheets.
In addition, it’s important to have the most up to date version of the Safety Data Sheets for any raw materials used by the company and finished goods manufactured on their behalf with every product change, and to review the SDSs on a regular basis to ensure nothing falls through the cracks. Importantly, there should also be appropriate document retention policies to comply with OSHA recordkeeping requirements.
OSHA Brief – Hazardous Communication Standard: Safety Data Sheets
OSHA 1910.1200 – Hazard Communications