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OSHA Hazard Communication Letters of Interpretation
MSDS requirements for products that are composed of a mixture of non-interacting chemicals.
- Issued
- Record type
- Interpretation
- Current standard
- HCS 2024, as amended
ILPI assessment: Additional current requirements apply
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its acceptance of a cover sheet plus component MSDSs should not be relied upon by itself to establish compliance with current requirements. Under the current HCS, mixture classification must follow paragraph (d)(3)(i) and the applicable criteria in Appendix A and Appendix B; the SDS must satisfy paragraph (g)(2) and Appendix D.
Component SDS information can still support classification under paragraph (d)(3)(ii). This is not a statement that every mixture requires new testing or that using component information is prohibited.
Last reviewed: .
About this ILPI assessment
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
Source: OSHA's original letter page.
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 [ILPI note: At issuance: original 1983 rule (PDF) | Current counterpart: HCS 2024, as amended] ) 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. [ILPI note: Current compliance also requires mixture classification and SDS content; see the assessment above.]
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 [ILPI note: At issuance: original 1983 rule (PDF) | Current counterpart: HCS 2024, as amended] 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
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1984-08-01.