Actually this is regulated under FIFRA, which over-rides all other labeling regs.

I think this is a matter of "too many government agencies spoil the SDS." SDS and occupational hazard labeling content are generally the responsibility of OSHA. However, assuming that this cleaner is also a consumer product, then the labeling can be governed by the Consumer Product Safety Commission, which has no jurisdiction over SDS content. It might also be governed by the EPA for pesticides/biocides, which has limited jurisdiction over SDS content. Of course, all of these government agencies has different priorities and requirements, which just about guarantees that everything will be confusing.

At least you were able to get an SDS. If you're ever in the mood to waste a few weeks, try getting one for dishwashing detergent.

While investigating an incident at my site recently, I came across an interesting issue. Interested in your thoughts.

The material involved is a commercially available spray disinfecting cleaner.

The container label listed these ingredients:

Active ingredients:

N-alkyl dimethyl benzyl ammonium chloride, 0.1%

N-alkyl dimethyl ethyl benzyl ammonium chloride, 0.1%

Inert ingredients:  98%

I pulled the SDS to look for more exposure information. The SDS (updated June 2017) did not list those active ingredients but did list the propellants used and EDTA.  

This is what the SDS says:

Chemical Name                                                CAS number       %

Butane                                                                 106-97-8               1-5

Diethylene glycol monobutyl ether            112-34-5               1-5

Propane                                                               74-98-6                 1-5

EDTA                                                                     64-02-8                 1-5

Composition comments                US GHS: The exact percentage (concentration) of composition has been withheld as a trade secret in accordance with paragraph (i) of 1910.1200.

I took that statement to mean the exact percentage of the ingredients listed were withheld, not that there were other ingredients not listed. It says percentage, not components. Though if you do the math, clearly something is missing from this list.

I thought that rather odd so I called tech support of the manufacturer. At first, they were confused as well, then told me that because the active ingredients were EPA registered materials, they did not have to be listed on the SDS. My reaction: Say what???

I have seen SDS that said proprietary mixture but still gave you a clue. But I had no idea an SDS could give no indication that there were other ingredients. 

No one I have asked at my organization has ever heard of this.

Have any of you? 

Signed,

No longer trusting SDS (which I suppose I should know better than to anyway).

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