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|Title: 12/10/1985 - Preparing a Material Safety Data Sheet under the trade secret provisions of the Hazard Communication Standard.|
|Record Type: Interpretation||Standard Number: 1910.1200|
December 10, 1985|
Mr. Ron Roberson
Dear Mr. Roberson:
This is in response to your letter of August 27, requesting an interpretation of the Hazard Communication Standard 29 CFR 1910.1200. Please accept our apology for the delay in responding.
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You requested clarification in several areas as noted below:
It would be acceptable to refer to the trade secret chemical either as "Component A" or as "proprietary sulfur compound".
If there is an OSHA permissible exposure limit and a TLV for the proprietary component A, then that value would need to be reflected on the MSDS. If there is a PEL and TLV for the proprietary component A it cannot be withheld from the MSDS.
The standard does not require the release of any volume percentages of any chemicals on the MSDS.
It would be acceptable to reference the health hazards associated with one chemical to that particular constituent; Ex. Health Hazards of Component A are....The health hazard information must include the signs and symptoms of exposure.
The Agency in the near future will be going through the rulemaking process to change the definition of a trade secret in the Hazard Communication Standard. Any changes or proposed changes to the standard will be published in the Federal Register. You may wish to periodically review the Federal Register in order to keep apprised of any changes.|
If I may be of further assistance on this matter please let me know.
John B. Miles, Jr., Director
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Mr. John B. Miles, Jr., Director|
Directorate of Field Operations
Occupational Safety & Health Administration
Washington, D.C. 20210
Dear Mr. Miles:
We are in the process of preparing material safety data sheets for approximately thirty Sensidyne products. A few of these products are electrolyte refill kits for our toxic gas detection sensors. Revealing the exact content of these electrolytes would be a disclosure of proprietary "know-how" in a highly-competitive market. We would like to provide material safety data information to our customers without revealing the actual components in order to protect legitimate trade secrets.
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Corporate Industrial Hygienist
Gas and Particulate Detection Systems
12345 Starkey Road, Suite E
Largo, Florida 33543
Phone (813) 530-3602/Telex 756223
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=19360&p_text_version=FALSE