April 1 -- Happy April Fool's Day and welcome to the April issue of 3E HazMat Matters! Please forward this newsletter to any colleagues who might find it useful or have them request a subscription by clicking here. For information on how to opt-out, see the instructions at the end of this email. In this Issue:
3E News 3E News ...........................................................................................................................
3E Company Ramps-Up REACH Practice to Help Industry Prepare for Ask the 3Experts.....................................................................................................
“We only have a dozen or so customers for our cooling tower maintenance products, but we ship to hundreds of their locations all over the country. It would make sense to send each of our customers a single copy of each MSDS, and any revisions, and for them to then distribute the MSDS to their satellite locations. Would I need a formal agreement from each customer ensuring that they will distribute our MSDSs properly in order to comply with the OSHA Hazard Communication MSDS distribution requirements?”
OSHA does not allow manufacturers to waive their MSDS distribution responsibilities. This means that no contract, or other formal agreement, with your customers can absolve you of your responsibility to distribute an MSDS to each location with the initial delivery of your product. Likewise, your responsibility to distribute a copy of significant MSDS revisions with the next shipment of product after the MSDS is revised, cannot be assumed by your customers.
One approach that you could employ to reduce your distribution obligations would be to distribute your products to one or more central customer locations and allow further product distribution to be your customer’s responsibility. In this manner you could reduce the number of sites to which you distribute product, and thereby reduce the number of sites to which you must distribute MSDS. Alternatively, you may be able to make use of Internet MSDS distribution. However, to do so you would have to provide “positive and verifiable” initial notification of availability and instruction for accessing the MSDS. You would also have to confirm that each customer facility has the equipment necessary to access your MSDS, and that they agree to use it to access all required MSDS. Even then, significant revision of MSDS health data would require that you take positive steps to inform your customers of the change and/or physically provide a revised MSDS with the next product purchase. - Michael Beckel
3E in the News............................................................................................................
The January/February issue of Compliance Magazine features an article on GHS written by 3E's very own Prabhu Natarajan. The full article can be viewed here. Tips N Tricks ....................................................................................................................
Did you know that 3E Online – MSDS allows you to cross reference your inventory against a variety regulatory lists at such as OSHA Carcinogens, ACGIH Threshold Limit Values and California Prop 65? Here's how:
Need the chemical name?
Special Offers ................................................................................................................. Don’t Ship that HazMat Without the Proper Label or Markings! It could cost your company up to $50,000 per incident, per day. Make sure your dangerous goods shipments are in compliance with 3E Transportation Classification Services. 3E Transportation specialists classify your inventory of hazardous materials for any mode-- ground, air or water. Shipping a new product that hasn’t already been classified? Call the 3E Transportation Hotline, which provides toll free 24-7-365 access to live specialists who respond with guidance on classification information, packaging, marking and labeling. Click here to learn more about 3E Company Transportation Services, call 1-800-346-6737 or visit our website, www.3ecompany.com. Events.......................................................................................................................... WEB SEMINARS Join 3E Company for a complimentary, educational Web Seminar "REACH – the new European chemicals regulation,” part of the 3E HazMat Management Web Seminar Series. During this web seminar, Jytte Syska, Vice President of Ariel Global Research and Operations, will provide an overview of the REACH requirements.
When: Thursday, April 12, 2007 CONFERENCES Come visit 3E at the following shows in April: ASUG Annual Conference & Vendor Fair COSTHA 2007 Annual Forum & Expo South Carolina Occupational Safety Council's Annual Conference ChemCon Asia 2007 EEI Spring 2007 Occupational Safety & Health Conference USER GROUPS All Ariel users are invited to join 3E Company in Singapore for our Ariel Customer Dinner during ChemCon. If you are attending ChemCon, or are local to the area, please join us for dinner on Thursday, April 26 at 8:00 pm. Members of 3E Company/Ariel management from the United States and Europe will be in attendance, making it a great opportunity to meet. Join us in an informal atmosphere, which will provide the opportunity to:
The dinner will be held at one of Singapore's most well-known restaurants, IndoChine Club Street. Indochine boasts an exotic mix of Vietnamese and French Asian cuisine that has made this restaurant one of Singapore's finest. 3E will provide complimentary roundtrip transportation from the Pan Pacific Hotel to IndoChine Club Street, which is about 10 minutes from the hotel. If you would like to attend this event, please send an email to Erica Miller. Feel free to extend this invitation to other members of your company as well and please note, you do not have to attend ChemCon in order to attend this event - the dinner is open to all 3E/Ariel customers! SPEAKING ENGAGEMENTS
Prabhu Natarajan, 3E's Director of Strategic Alliances and Product Marketing, will be discussing REACH at the Semiconductor Environmental Safety & Health Association's (SESHA) Annual Conference in Santa Clara, CA on Wednesday, April 11, 2007 at 11:15 AM.
Mr. Natarajan will also be speaking at the National Association of Environmental Professionals (NAEP) Annual Conference in Orlando on Developing a Full Lifecycle Approach to EH&S Management Systems. His session is on Monday, April 23, 2007 at 1:30 PM.
3E's experts will be speaking during three different sessions during ASUG's Annual Conference. Jillaine Dellis, Vice President of Ariel Global Research and Operations, will be speaking on discussing the latest changes in global regulatory requirements and their impact on SAP EH&S on Monday, April 23, 2007, from 12:30 PM - 1:30 PM. Wolf Wittke, Manager of Implementation Strategy and Services, will be presenting on "Managing Change in Regulatory Compliance Requirements within SAP EH&S on Tuesday, April 24, 2007, from 4:00 PM - 5:00 PM. Julia Tsvetkova, Product Manager, will be presenting "Integrating Software tools and Regulatory Content for SAP EHS with Core Business Processes to Unlock Hidden Value" on Wednesday, April 25, 2007 from 2:30 PM - 3:30 PM.
Alex Ortiz, Director of Research and Development, will be speaking at the 2007 ChemCon conference in Singapore. Mr. Ortiz will provide an overview of chemical control legislation in Latin American countries such as Mexico, Brazil, Venezuela, Chile, etc. He is speaking during session #10 on Thursday, April 26, 2007.Industry Articles: News You Can Use...............................................................................
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