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Hazard communication sheets for flavor extracts

Summary A senator asked whether a small flavor-extract maker had to produce costly hazard data sheets. OSHA said the rule might require sheets, but hazard evaluation could rely on existing literature and supplier information rather than new testing. It also said the food-labeling scheme exempted the extracts from OSHA's labeling requirement.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1986-03-21
Date issued
March 21, 1986
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1910 Hazard Communication Safety Data Sheets
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

March 21, 1986

The Honorable Daniel P. Moynihan
United States Senate
[Recipient address omitted]
Dear Senator Moynihan:

This is in response to your letter dated March 4 on behalf of your constituent Mr. Barry Striem of Essential Products Co., Inc., regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS). Mr. Striem expressed concern about the application of the HCS to flavor extracts used in his business.

The HCS may in fact require the transmission of material safety data sheets for flavor extracts. The standard requires that chemical manufacturers make an evaluation of their product's toxicity and physical properties. This evaluation does not require testing. The standard's "hazard determination" procedures allow the evaluator to rely on the literature that is available.

In the case of mixtures, chemical manufacturers may rely on the material safety data sheets received from their suppliers. The material safety data sheet received may serve as the basis for your constituent's evaluation of the products he sells.

The HCS exempts flavor extracts from its labeling requirements. These products already require labeling under the Federal Food, Drug and Cosmetic Act.

Members of my staff are available to assist Mr. Striem in complying with the HCS. Mr. Striem may contact Mr. David Smith of OSHA's Office of Health Compliance Assistance at (202) 523-8036 for help.

Please feel free to contact us again if further assistance is needed.

Sincerely,
Patrick R. Tyson
Acting Assistant Secretary

[Requester letter reproduced on OSHA page; omitted here.]

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