XXXINSERT DESKTOP ENTRY NAME HEREXXXINSERT MOBILE ENTRY NAME HERE
The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995!
The history and philosophy behind this resource.
A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics.
Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term.
An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more.
A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers.
Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet.
Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources.
Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors
You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard
Commercial suppliers of SDS authoring and management software as well as cloud compliance services.
Commercial companies that will create SDS's for your specific needs as well as SDS translation companies.
Safety signs, banners, and scoreboards? Get yours at Safety Emporium!
Title: 01/20/1987 - Clarification of the terms "appropriate hazard warning" and "mandatory".
ILPI Notes: This interpretation is based on and references HCS 1986 which was replaced by HCS 1994, both of which are now obsolete. It references portions of the standard that have since been deleted or changed. The conclusions are not valid under the current regulation and this letter is presented for historical purposes only.
January 20, 1987
Mr. D. S. Richardson 2655 Harland Drive Hudson, Ohio 44236
Dear Mr. Richardson:
This is in response to your letter of December 13, 1986, requesting clarification of the terms "appropriate hazard warning" and "mandatory" as used in the Occupational Safety and Health Administration's (OSHA) (OSHA) Hazard Communication Standard [in context: HCS 1994 | current regulation: HCS 2012].
Concerning "appropriate hazard warning," OSHA's guidelines to its compliance staff on the Hazard Communication Standard OSHA Instruction CPL 2-2.38A [obsolete; in context: CPL 2-2.38D | current regulation: CPL 02-02-079] Change 1, page A-11, enclosed states that the specific hazards indicated in the standards definition for "physical" and "health" hazards must be used in evaluating the appropriateness of specific warnings. In the example you presented, if the only scientific information available is the LC(50) of 5 milligrams per kilogram administered orally to rats, "highly toxic if ingested" may be the appropriate warning [obsolete; hazard wordings are now rigidly defined using hazard statements]. If the chemical causes specific target organ effects when ingested, then the specific target organ effects would be appropriate.
As stated in Appendix B of the Hazard Communication Standard [in context: HCS 1994 | current regulation: HCS 2012], the hazard determination [obsolete; a much more comprehensive hazard classification is now required] is performance-oriented and relies heavily on the professional judgment of the evaluator. Nevertheless, the hazard determination must examine all relevant data and produce a scientifically defensible evaluation. The results of any studies which are designed and conducted according to established scientific principles must be reported if statistically significant health effects are found. If these statistically significant health effects are known to the target organ level, then these health effects would be "appropriate."
If only general health effects are known, then it would be "appropriate" to list these on the label. [obsolete; the current regulation has specific labeling requirements that specify the wording to be used.
The Hazard Communication Standard at 29 CFR 1910.1200(d)(2) [in context: HCS 1994 | current regulation: HCS 2012]
states, Appendix A shall be consulted for the scope of health hazards covered. The term "mandatory" refers to the requirement to consult Appendix A [in context: HCS 1994 | current regulation: HCS 2012 for the scope of health hazards.
Please feel free to contact us, if further assistance is needed.
Sincerely,
John A. Pendergrass Assistant Secretary
The original official public domain version of this document is available from OSHA at XXXOSHAURL.