December 10, 1985 Mr. Ron Roberson Corporate Industrial Hygienist Sensidyne Inc. Gas and Particulate Detection Systems 12345 Starkey Road, Suite E Largo, Florida 33543 Dear Mr. Roberson: This is in response to your letter of August 27, requesting an interpretation of the Hazard Communication Standard 29 CFR 1910.1200. Please accept our apology for the delay in responding.

Keep your workplace clean and organized with PPE dispensers from Safety Emporium.

You requested clarification in several areas as noted below:

1. Is it acceptable to state "proprietary component A" or must you state "proprietary sulfur compound"?

   It would be acceptable to refer to the trade secret chemical either as "Component A" or as "proprietary sulfur compound".

2. How does one state a Threshold Limit Value (TLV) for a proprietary compound? Can this be omitted or can several TLV's be stated if all are appropriate?

   If there is an OSHA permissible exposure limit and a TLV for the proprietary component A, then that value would need to be reflected on the MSDS. If there is a PEL and TLV for the proprietary component A it cannot be withheld from the MSDS.

3. Can volume percentages be omitted for proprietary components?

   The standard does not require the release of any volume percentages of any chemicals on the MSDS.

4. Under Health Hazard is it acceptable to refer to components as "Component A" or as "one component"? Can overexposure symptoms be discussed without divulging chemical families?

   It would be acceptable to reference the health hazards associated with one chemical to that particular constituent; Ex. Health Hazards of Component A are....The health hazard information must include the signs and symptoms of exposure.

The Agency in the near future will be going through the rulemaking process to change the definition of a trade secret in the Hazard Communication Standard. Any changes or proposed changes to the standard will be published in the Federal Register. You may wish to periodically review the Federal Register in order to keep apprised of any changes. If I may be of further assistance on this matter please let me know. Sincerely, John B. Miles, Jr., Director Directorate of Field Operations

Comply with state and federal regulations with hazardous waste labels fromSafety Emporium.

Mr. John B. Miles, Jr., Director Directorate of Field Operations Occupational Safety & Health Administration Washington, D.C. 20210 Dear Mr. Miles: We are in the process of preparing material safety data sheets for approximately thirty Sensidyne products. A few of these products are electrolyte refill kits for our toxic gas detection sensors. Revealing the exact content of these electrolytes would be a disclosure of proprietary "know-how" in a highly-competitive market. We would like to provide material safety data information to our customers without revealing the actual components in order to protect legitimate trade secrets.

Encourage good work habits with safety signs, banners and pins from Safety Emporium.

1. What is acceptable wording under "Ingredients". Is it acceptable to state "proprietary sulfur compound"?

2. How does one state a TLV for a proprietary compound? Can this be omitted or can several TLV's be stated if all are appropriate?

3. Can volume percentages be omitted for proprietary components?

4. Under "Health Hazards" is it acceptable to refer to components as "Component A" or as "one component"? Can overexposure symptoms be discussed without divulging chemical families?

Sincerely yours,

Ron Roberson
Corporate Industrial Hygienist
SENSIDYNE INC.
Gas and Particulate Detection Systems
12345 Starkey Road, Suite E
Largo, Florida 33543
Phone (813) 530-3602/Telex 756223