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Inapplicable fields on material safety data sheets

Summary OSHA clarified whether an earlier interpretation allowing omitted inapplicable safety data sheet sections applied only to computer-generated sheets. It said the rule sets no fixed format, so preparers may leave out fields that do not apply to a chemical on any kind of sheet. The guidance matters to chemical suppliers designing safety data sheets.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1988-05-12-0
Date issued
May 12, 1988
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.

May 12, 1988

MEMORANDUM FOR: BRUCE HILLENBRAND, DIRECTOR Directorate of Federal-State Operations
FROM: THOMAS J. SHEPICH, DIRECTOR
Directorate of Compliance Programs
SUBJECT: Clarification of Interpretation on Material Safety Data Sheet Requirements Under the Hazard Communication Standard

Ms. Barbara Bryant, of your staff, has brought to our attention a concern that was raised during the February meeting of the Occupational Safety and Health State Plan Association held in Chapel Hill, North Carolina. The concern has to do with a past interpretation (copy attached) made by this Directorate regarding leaving off a section on a material safety data sheet (MSDS) when the pertaining information does not exist. Some OSHA personnel have mistakenly interpreted this policy to apply only to computer generated MSDS.

It was and still is our policy that the interpretation applies to any type of MSDS. Since the standard is performance-oriented and no MSDS format is specified, employers are free to develop MSDSs that are designed for a specific chemical. For example, if an employer develops a MSDS for a chemical which is not a carcinogen, a space addressing carcinogenicity does not have to be provided on the form.

If you have any questions, please feel free to contact Steve Simon on 523-8036.

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