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Title: 03/07/2007 - Use of generic MSDSs written by third-party companies and employer responsiblities when using an online MSDS service. | |
Record Type: Interpretation | Standard Number: 1910.1200, 1910.1200(g), 1910.1200(g)(2) |
March 27, 2007
Mr. Michael Boozer
President
ChemReport, Incorporated
4515 Washington Road
Kenosha, WI 53144
Dear Mr. Boozer:
This 400,000+ MSDS database from Safety Emporium features manufacturer-specific sheets.
Scenario 1: You describe companies that provide employers with electronic MSDS access services. These services are provided either online or on CD-ROM. You state that these companies provide generic MSDSs for chemical products and that these MSDSs do not contain the name of any specific chemical manufacturer, and that they may contain incomplete information regarding the chemical composition and hazards of the substance. Your concern is that these types of generic MSDSs and the associated supply services do not meet the intent of the HCS.
Question 1: Do generic MSDSs written by third-party companies meet the requirements of the hazard communication standard?
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Your letter also stated that "generic" MSDSs may contain health and safety hazard information that may not be indicative of the latest available heath information for those substances and that the information reflected on the generic MSDSs may be "substantially different or lacking." As previously stated, the "generic MSDSs" described in your letter would not meet the intent of the HCS if it lacks critical identifying information. The HCS is a performance-oriented standard, however, and although there are specific requirements for MSDS content, there is some variability in terminology that may be found on MSDSs from different manufacturers for chemical products with primarily the same content. The scientific accuracy of the information provided is the essential requirement.
Question 2: Under what conditions can employers rely on on-line MSDS services to make available to them the MSDS for a specific chemical used by that employer when the employer has not provided the service with the MSDS document?
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The following scenario provides further clarification to your question. If an employer had supplied an on-line MSDS service with copies of the MSDSs for the specific chemicals being used at his or her workplace, and the service was able to make that specific MSDS information immediately accessible pursuant to an on-line request, then those conditions would ensure that the intent of the standard was being met. Please note that OSHA has allowed electronic access to MSDSs for many years, and there are several existing letters of interpretation that provide additional discussion on this issue. Further information regarding MSDS electronic access, as well as many other topics can be found OSHA's web site at http://www.osha.gov.
Sincerely,
Richard E. Fairfax, Director
Directorate of Enforcement Programs
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25738&p_text_version=FALSE