Are MSDSs subject to the Record Retention Requirements of 29 CFR 1910.1020?
OSHA gave employers two options under the record retention requirements for records of exposure data. The first and preferred option is to keep a record of the chemical(s), the time of use, and the location. The second option is to maintain a copy of the MSDS. The wording of the regulation is such that, if the second option is used, no “when” and “where” information is needed. In either case, employee exposure records must be retained for 30 years, after the employee leaves employment. This is discussed in an internal OSHA memorandum, dated December 12, 1986 from Jon Miles to Frank Strasheim. The memorandum is available on the OSHA CD-ROM.
