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OSHA Hazard Communication Letters of Interpretation
Evaluation of a "generic" Material Safety Data Sheet (MSDS) for copper/copper alloys.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: OSHA does not approve SDSs; old optional formats are superseded
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its main conclusion remains consistent: OSHA does not approve an SDS, and preparing a generic sheet does not shift responsibility for accurate hazard information away from the responsible supplier.
Under the current HCS, apply hazard classification, anticipated-use hazards, similar-mixture conditions and required SDS headings and order, no-information statements, and Appendix D. The former any-format/OSHA Form 174 approach is obsolete; the historical Form 174 (PDF) is not a current compliant SDS template. Consider downstream processing, including dust and fume, and applicable exposure-control standards; no copper/alloy sheet or product is approved here.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
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 [ILPI: Original HCS 1987 context (PDF) · Current HCS] 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.
Any format for a MSDS is acceptable, as long as the information conforms to the requirements of paragraph (g) of 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]. OSHA has published a sample MSDS, form number OSHA 174 [ILPI note: You can download this in historical PDF format]. This is an optional form which may be used to comply with 29 CFR 1910.1200(g) [ILPI: Original HCS 1987 context (PDF) · Current HCS].
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This format statement is obsolete. Current required SDS headings and order, no-information statements, and Appendix D governs SDSs. A shared sheet must satisfy similar-mixture conditions and accurately cover actual hazards and composition; Form 174 is historical only.]
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 https://www.osha.gov/laws-regs/standardinterpretations/1993-01-06.