Hazardous chemical inventory in a medical office

December 22, 1992
Dr. Rupert Quentin Bliss
[Recipient address omitted]
Dear Dr. Bliss:
This is in response to your inquiry of October 7, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.
You requested assistance in preparing an inventory of the chemicals in your office and the hazard class for each of the chemicals in a compound. First, we will clarify your responsibility in making an inventory of chemicals in the work place: employers must list the names of all hazardous chemicals used in the workplace by using the identity that is referenced on the material safety data sheet (MSDS). This identity is often a common name, such as the product or trade name (i.e., Lime-A-Way). The rule does not require that you indicate the hazards of each chemical on the list; employees are informed of hazards through MSDSs and labels.
Since this may be a point of confusion for you, we will briefly explain the HCS's hazard determination requirements. Chemical manufacturers must either determine the hazards of the product as a whole or assume that the mixture presents the same health hazards as its components. In cases where a chemical mixture or compound has not been tested as a whole, the manufacturer's MSDS must list all of chemical components that have been determined to be hazardous which comprise one percent or greater of the mixture, or 0.1 percent or greater for components that are considered carcinogenic. In either case, where the hazard has been determined for the mixture or the individual components of the mixture, all of the information should be provided for the employer and employees in the MSDS.
If you feel that the MSDS provided to you does not adequately notify you of all hazards, you may contact the chemical manufacturer for more information or refer the inadequacy to your OSHA area office:

[Jacksonville Area Office
Ribault Building, Suite 227
1851 Executive Center Drive
Jacksonville, Florida 32207
Phone: (904) 232-2895
FAX: (904) 232-1294]

We hope this information is helpful. If you have any further questions please feel free to contact [the Office of Health Enforcement at (202) 693-2190].
Sincerely,
Ruth Mccully,
Director
Office of Health Compliance Assistance
[Corrected 3/19/2009]

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