08/01/1984 - MSDS requirements for products that are composed of a mixture of non-interacting chemicals

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Title: 08/01/1984 - MSDS requirements for products that are composed of a mixture of non-interacting chemicals.
Record Type: Interpretation	Standard Number: 1910.1200

ILPI Notes: This interpretation is based on and references the original HCS 1986 which, along with HCS 1994 is now obsolete. It references portions of the standard that have since been deleted or changed. This answer is now incorrect under the current regulation (HCS 2012) which requires that all mixtures undergo hazard classification as discussed in Section A.0.4 of Appendix A of HCS 2012; the SDS must include those classifications. Therefore, this letter is presented for historical purposes only.

August 1, 1984

Robert A. Wiesboeck, Manager
Atlanta Technical Center
USS, Agri-Chemicals,
Division of United States Steel Corporation
685 Dekalb Industrial Way
Decatur, Georgia 30033

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Dear Mr. Wiesboeck:

This is in response to your inquiry dated June 22, concerning the completion of Material Safety Data Sheets (MSDS), under the Occupational Safety and Health Administration's (OSHA) Hazard Communication standard (29 CFR 1910.1200 [in context: HCS 1994 | current regulation: HCS 2012] ) for products that are composed of a mixture of non-interacting chemicals.

For such products, you propose that component chemical MSDS be attached to a cover sheet identifying the mixture product and listing all constituents.

This approach is acceptable as long as the hazards associated with the mixture are not different from that of its components. [This is no longer correct; see Section A.0.4 of Appendix A of HCS 2012]

Please contact us if further assistance is needed.

Sincerely,

John B. Miles, Jr., Director
Directorate of Field Operations

June 22, 1984

Mr. John Miles
Director
Field Operations
OSHA
200 Constitution Avenue, N.W.
Room N-3603
Washington, D.C. 20210

Dear Mr. Miles:

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Recently Ms. J. Silk of your office was helpful in clarifying for me a requirement of the OSHA Hazard Communication Act [in context: HCS 1994 | current regulation: HCS 2012] as it applies to mixtures.

The question was whether MSDS's for non-interacting mixtures of OSHA hazardous materials can be prepared by composing a cover sheet listing the hazardous and nonhazardous components, and attaching the manufacturers MSDS for the hazardous materials as shown on the attached sample.

It is understood that this can be done only for non-interacting materials.

Please respond to the proposal in question by letter to give me a copy for my file.

Your prompt answer is greatly appreciated.

Very truly yours,

USS AGRI-CHEMICALS

Robert A. Wiesboeck
Manager
Atlanta Technical Center

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