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Safety data sheets for diluted chemical products

Summary A manufacturer asked whether diluting a product to working strength requires a new material safety data sheet. OSHA said the chemical manufacturer’s sheet should describe expected downstream uses and remains applicable when the product is diluted according to its directions. The letter referred separate SARA Title III reporting questions to EPA.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-07-31
Date issued
July 31, 1989
Status
Active
Status last verified October 10, 2026

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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.

July 31, 1989

Mr. Charles E. Lindsay
Lindsay Hardwoods, Incorporated
[Recipient address omitted]
Dear Mr. Lindsay:

This is in response to your correspondence of May 2, regarding SARA Title III reporting requirements under sections 311, 312 and 313.

The Hazard Communication Standard (HCS), 29 CFR 1910.1200, requires a material safety data sheet (MSDS) to be developed for each hazardous chemical produced by a manufacturer. The MSDS developed by the chemical manufacturer should contain hazard information on the chemical for all its expected uses downstream. Therefore, as Jim Johnston mentioned to you, you are not required to generate a new MSDS when the product is diluted to its working strength, according to the manufacturer's directions. The MSDS received from the manufacturer is applicable to the diluted mixture.

The SARA Title III reporting requirements are administered by the Environmental Protection Agency. Your letter has been forwarded to the EPA for their response at the following address:

The Environmental Protection Agency
Emergency Planning and Community Right to-know Information Hotline
Attn: Ms. Minda Sarmiento
OS-120 401 M Street, S.W.
Washington, D.C. 20460

We hope this information is helpful to you. Please feel free to contact us again if further assistance is needed.

Sincerely,
Patricia K. Clark, Acting Director
Directorate of Compliance Programs

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