Optional numeric and color coded chemical hazard labels

July 10, 1992

Thomas A. Dawson, D.D.S., P.C.
[Recipient address omitted]
Dear Dr. Dawson:

This is in response to your letter dated February 10, to the Michigan Department of Public Health concerning requirements for rating of hazards on Material Safety Data Sheets (MSDS). Your letter was referred to the Occupational Safety and Health Administration (OSHA) for a response since you recommended that these hazard ratings be included as part of the MSDS requirements of the Federal Hazard Communication standard.

The Hazard Communication standard allows any labeling format to be used, as long as the labels include the basic required information regarding the chemical, i.e., the identity, the appropriate hazard warning(s), and the name and address of the chemical manufacturer. As indicated by the Michigan Department of Public Health, numerical rating or color-coded labels are strictly a voluntary, optional means of identifying hazards of materials. We are aware that a number of dentists have purchased compliance packages that include such labels, but it is not necessary to re-label containers received from manufacturers to indicate numerical ratings or color codes. Furthermore, you may use information from the manufacturer's label to label other containers in the workplace into which you transfer chemicals. As numerical ratings or color codes are not required under OSHA's labeling provisions, the Agency has no plans to consider modifying the MSDS provisions to add this information.

As you know, the State of Michigan is administering its own occupational safety and health program under a plan approved and monitored by Federal OSHA. States are required to adopt occupational safety and health standards at least as effective as those promulgated by Federal OSHA. Michigan has adopted a rule identical to the Federal which applies to all employers with employees exposed to hazardous chemicals in the workplaces. Thus, the Michigan Hazard Communication standard is currently in effect in your state.

In addition, Michigan offers free on-site consultation services to those employers who request guidance on compliance with occupational safety and health standards. For information regarding either the consultation services or the requirements of the Michigan Hazard Communication Standard, you should contact:

Vernice Davis Anthony Director
Michigan Department of Public Health
3423 North Logan Street
Box 30195
Lansing, Michigan 48909
Telephone: (517) 335-8022

We hope that this information is helpful to you. If we may be of further assistance, please do not hesitate to contact us.

Sincerely,
Bruce Hillenbrand, Director
Federal-State Operations

[Earlier Michigan agency correspondence and requester letter reproduced on OSHA page; omitted here.]