The OSHA guidance is correct, but it's based on the old Hazard Communication standard that's been replaced by a new one, based on the "Globally Harmonized System." The legal designation for the standard is 29 CFR 1900.1200. You can find it on the OSHA website, www.osha.gov.

 

Drugs and drug ingredients are exempt from labeling requirements only when they subject to FDA labeling. (29 CFR 1900.1200(b)(5)(iii)

 

Laboratories have to maintain labels and safety data sheets sent by the supplier, and obtain a safety data sheet if an employee requests one. And, as the guidance states, if you ship anything out - other than the FDA labeled materials - you have to supply labels and safety data sheets. (b)(3)

 

That's the law. Of course, best practice is to get as much information as possible about what you are working with. I'd demand a safety data sheet from anyone sending you any chemical or mixture. And in almost every case, the supplier has the legal requirement to send one.

 

Mike Wright