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MSDS for Drug Samples?

Q: Do we need MSDS for the boxes of drug samples we give to patients?

A: No, Material Safety Data Sheets are not required for drug samples distributed to patients.

Need help with OSHA compliance? Ask Dr. Dunn or browse our helpful osha manuals & compliance programs.

Posted by Quality America on December 30, 2005 | Comments (3)

Comments

"Do we need MSDS for the boxes of drug samples (that) we give to patients?"

Unfortunately the person posing this question did not identify whether "we" means an Employer that is subject to the guidelines of the HCS.

Your response was correct in that the final distribution to the patient does not need to be accompanied by and MSDS.

However, assuming that the person asking the question is a Pharmaceutical Rep, Doctor's office, Hospital, or other Health Care Provider then they would likely fall under the requirements of the HCS MSDS guidelines and requirements placed upon the Employer by 1910.1200.

Personally I cannot imagine that a professional Health Care provider, "Distributor" of products that may pose a Health Hazard (hazardous materials), etc would even presume to have in his/her possession a "boxes of sample(s)" of drugs without accompanying documentation whether they are exempt from the requirement or not.

http://www.ilpi.com/msds/osha/I19890620A.html

Posted by: D Hutton at March 17, 2006 11:07 AM

Well if you're not a lawyer, I'm a monkey's uncle! We had replied to a previous blogger that MSDS aren't required for sample meds. Specifically, the HazCom regulations require MSDS for all drugs except for those in solid, final form for direct administration to the patient (i.e., tablets, pills, or capsules). I don't understand what your last sentence refers to, but virtually every doctor's office in the US keeps sample medications for their patients, and it's not a requirement for them to keep "accompanying documentation" that they're exempt from having MSDS for them.

Posted by: Dr. Dunn at April 4, 2006 02:28 PM

Here is the link to OSHA's letter of interpretation that exempts FDA-approved drugs in solid final form (i.e., tablets or pills) from Hazard Communication Standard (HCS) requirements:

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p;_id=21231

Posted by: Sarah Alholm at February 20, 2007 05:12 PM




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