| 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: 10/02/2015 - The labeling elements required on the safety data sheet (SDS) under the Hazard Communication Standard (HCS 2012) | |
| Record Type: Interpretation | Standard Number: 1910.1200(g)(2) |
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
Slash your extinguisher maintenance costs with the revolutionary Rusoh Eliminator Self-Service Refillable ABC Fire Extinguishers from Safety Emporium.
October 2, 2015
Ms. Tammy L. Blakeslee, CIH
President
EnviroNet LLC
P.O. Box 386 M.O.,
Shrewsbury, MA 01545
Dear Ms. Blakeslee:
Thank you for your April 12, 2015, letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP). In your letter you requested guidance on the labeling elements required on the safety data sheet (SDS) under the Hazard Communication Standard (HCS 2012), 29 CFR 1910.1200. This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased scenario and question are presented below, followed by our response.
Scenario: EnviroNet LLC needs to modify and omit the Globally Harmonized System (GHS) precautionary statements with certain packaged material because the statements are not appropriate. The product in question is flammable and sold in small glass bottles and 5-gallon steel drums. However, the precautionary statement referring to grounding and bonding applies only to the steel drums, and not to the glass bottles.
Accordingly, we have two sets of label elements that need to be communicated on two different product labels with the only difference being the precautionary statements.
Question: We have a single SDS for this product. Is it acceptable to list the grounding and bonding precautionary statement in Section 2 of the SDS even though it does not apply when the product is packaged in glass bottles?
Response: Yes, it is acceptable to list all precautionary statements on a single SDS even though some of the precautionary statements do not apply to the product when placed in glass containers. Paragraph 29 CFR 1910.1200(g)(2) requires the SDS to include precautionary statements as outlined in Appendix D to §1910.1200 - Safety Data Sheets (Mandatory). A statement that the grounding and bonding precautionary statement does not apply when the product is shipped in glass bottles may be added to Section 7 of the SDS, Handling and Storage.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To ensure that you are using the correct information and guidance, please consult OSHA's website at https://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Sincerely,
Thomas Galassi, Director
Directorate of Enforcement Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2015-10-02.