Material safety data sheet format and coverage

November 20, 1995

The Honorable L. F. Payne
U.S. House of Representatives
[Recipient address omitted]
Dear Congressman Payne:

Thank you for your letter of June 28, addressed to Joseph A. Dear, Assistant Secretary for the Occupational Safety and Health Administration (OSHA) on behalf of your constituent, Mr. Alan Cooper. Mr. Cooper is the Director of Riverside Healthcare Center in Danville, Virginia, and is concerned about the Occupational Safety and Health Administration's Hazard Communication Standard (HCS), specifically, the requirements for material safety data sheets (MSDS).

The HCS is a performance standard, as opposed to a specification standard, and does not require a specific format for MSDS. The requirements are that the MSDS must be in English and must contain, as a minimum, certain information about the hazardous chemical being addressed. This is spelled out in paragraph 1910.1200(g) of the HCS. Preparers of MSDSs are free to use whatever format they choose, as long as all the required information is presented. OSHA has provided a non-mandatory form (OSHA 174) to serve as a guide, and this is used by some preparers.

In 1993, the American National Standards Institute (ANSI) published the American National Standard for Hazardous Industrial Chemicals - Material Safety Data Sheets - Preparation, ANSI Z400.1-1993. The ANSI standard recommends titles and specific order for the sections of a MSDS, and recommends sixteen sections, the first ten of which are the OSHA required elements. This format has been widely accepted and is in use throughout the world. Copies, at $80 each, may be purchased from ANSI, 11 W. 42nd Street, New York, New York 10036.

While the ANSI standard does not exactly meet all of Mr. Cooper's recommendations, it does require that the information on the product identity (name) and the company, including the telephone number, appear in the first section; that the hazards be identified in section three; and that first aid information appear in section four. In many cases this information would appear on the first or second pages. Additionally, ANSI makes other recommendations as to the appearance of the finished document, including type size.

Mr. Cooper is incorrect in stating "Every product in America must have a MSDS sheet." Only chemicals which meet the OSHA definition of "hazardous" are required to have MSDSs. These criteria are found in section c. of the HCS. Employers should discourage suppliers from sending MSDSs for non-hazardous products.

For your information, the National Advisory Committee on Occupational Safety and Health (NACOSH) held a public meeting of its hazard communications workgroup October 19 and 20, 1995. The workgroup was covered to identify ways to improve chemical hazard communication and the right to know in the workplace. A copy of the Federal Register notice which gives the details of the meeting is attached.

I hope this information is helpful.

Sincerely,
Joseph A. Dear
Assistant Secretary

Enclosure

[Earlier correspondence reproduced on OSHA page; omitted here.]