01/06/1993 - Evaluation of a "generic" Material Safety Data Sheet (MSDS) for copper/copper alloys

Interactive Learning Paradigms, Incorporated


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!

XXXPrevNext
Title: 01/06/1993 - Evaluation of a "generic" Material Safety Data Sheet (MSDS) for copper/copper alloys.
Record Type: InterpretationStandard Number: 1910.1200

    January 6, 1993

    Mr. Franklin Brown, Jr.
    Executive Vice President
    Copper & Brass Servicenter Association, Incorporation
    Adams Building, Suite 109
    251 West Dekalb Pike
    King of Prussia, Pennsylvania 19406

    Dear Mr. Franklin:

    This is in response to your letter of November 25, 1992 to the Occupational Safety and Health Administration (OSHA) requesting an evaluation of a "generic" Material Safety Data Sheet (MSDS) for copper/copper alloys prepared by your Association.

    According to the inquiry you claim, "the MSDS was developed with the assistance of, and subsequently the approval of, OSHA". OSHA does not approve MSDSs. OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200 does, however, require that the hazards of all chemicals produced or imported into the United States be evaluated and that information concerning any associated health or physical hazards be transmitted to employees via comprehensive hazard communication programs. The programs are to include container labeling and other forms of warning, MSDSs and employee training.

    It is important to note, that the chemical manufacturer and the importer have the primary duty for hazard evaluation. Whoever does the evaluation is responsible for the accuracy of the information. The evaluation must assess the hazards associated with the chemicals including those hazards related to any anticipated or known use which may result in worker exposure.

    (sponsored information)

    400,000 MSDS's in your shirt pocket...
    MSDS Library
    with the MSDS Hazard Communication Mobile Desktop from Safety Emporium.

    Any format for a MSDS is acceptable, as long as the information conforms to the requirements of paragraph (g) of 29 CFR 1910.1200. OSHA has published a sample MSDS, form number OSHA 174 [ILPI says: You can download this in HTML format from OSHA's web site]. This is an optional form which may be used to comply with 29 CFR 1910.1200(g).

    Since an MSDS for copper/copper alloys was forwarded to us, it is assumed that the chemical manufacturer has performed a hazard determination on the product and has found it to contain hazardous chemicals. OSHA does not prohibit the manufacturer of the product in question from stating that the product "meets OSHA requirements" if the manufacturer is providing MSDS(s) and hazard information as required under the HCS.

    Additionally, information in the MSDS may need to conform to the language contained in other OSHA health standards. Specifically, workplace situations where copper/copper alloy is used. For example, depending on the ingredients contained in the metal and/or alloy and it's manner of use, employee protection may be required, including ventilation controls, personal protective equipment, clothing or gloves, or other applicable precautions. This assessment should be made by the manufacturer as it relates to the downstream use of copper/copper alloy.

    I hope this discussion will be useful to you in responding to your Association. Please contact me if you have any further questions.

    Sincerely,

    Roger A. Clark Director
    Directorate of Compliance Programs


The original official public domain version of this document is available from OSHA at XXXOSHAURL.