Rubber Industry

ARPM Rubber Manufacturing Blog

The ARPM Rubber Manufacturing Blog allows members to rapidly communicate with each other. Post both questions and answers to questions that other ARPM members have about any industry topic from material and process issues to R&E Tax Credits and other business issues.

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Rubber Manufacturing Blog / Materials / SDS required for finished molded products?
Posted:  17 Jun 2015 15:22
We are getting requests from some customers to supply them with SDS documents on our finished, vulcanized, molded products. 
I was always under the impression that MSDS/SDS documents were not required and did not apply to inert, finished product.
Is this true?  If so, is there a source on-high that I can quote to justify my position?
If this is not true, where can I go to get these created for my finished products?

Charlie Braun
Posted:  17 Jun 2015 15:53
Hi Charlie,

It sounds like your finished products can be considered as "articles" and would likely be exempt from the SDS requirement. OSHA 29 CFR 1910.1200(c) defines an article as "…a manufactured item other than a fluid or
particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has
end use function(s) dependent in whole or in part upon its shape or design during end use; and
(iii) which under normal conditions of use does not release more than very small quantities, e.g.,
minute or trace amounts of a hazardous chemical (as determined under paragraph (d) of this
section), and does not pose a physical hazard or health risk to employees."

Scho Wolers
Posted:  24 Jun 2015 14:42   Last Edited By: 1st resource
Here is what I have regarding this:  “Our products, comprised of rubber and other materials, do not require Material Safety Data Sheets.  They are "articles" within the meaning of 29 C.F.R. 1910.1200 (c). They are formed to a specific shape or design during manufacture, have an end use dependent on their shape or design, and do not release or otherwise result in exposure to hazardous chemicals under normal conditions of use.”

This is from our chemist.

Hope this helps.

Regards,

Rob Trippett
Equipment Specialist
Lavelle Industries Inc