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|Title: 04/07/1986 - Labeling and MSDS requirements for product containing trace quantities of ethylene oxide.; Criterion that must be satisfied in order to assert that a product or operation is exempt for the EtO Standard|
|Record Type: Interpretation||Standard Number: 1910.1200; 1910.1047(a)(2)|
April 7, 1986|
Ms. Diana L. Wilbur
Dear Ms. Wilbur:
This is in response to your letter of September 9, 1985, concerning the Occupational Safety and Health Administration's (OSHA) standards for ethylene oxide (EtO) (29 CFR 1910.1047) and for hazard communications (29 CFR 1910.1200). I apologize for the delay in responding to your inquiry.
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With regard to your first question, the ethylene oxide standard in 29 CFR 1910.1047(a)(2) states:
You state in your letter that your supplier of the surfactants that contain EtO has made the determination that their product is exempt from the standard pursuant to paragraph (a)(2). Your supplier, therefore, is required under 29 CFR 1910.1047(a)(3) to maintain the records of objective data required in paragraph (k)(l) to support their claim that their product is exempt.|
Since your company formulates new products from the surfactants, the expected conditions of processing, use, or handling of your products may be different from those envisioned by your supplier, and thus may result in different levels of employee exposure to EtO. Therefore, in order to establish that your products are exempt under the provisions of paragraph (a)(2), a determination must be completed in accordance with paragraph (k)(1). If the expected condition of processing, use, or handling for your products are similar to the conditions assumed by the supplier for their products, then the supplier's data could be used as the basis for your determination. Also, you are required under paragraph (a)(3) to maintain the records of the data used to support your exemption claims for your products. You are not required to supply this data to your customers.
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With regard to your second question concerning labels, if you determine that your products are exempt from the EtO standard, then the label specified in 29 CFR 1919.1947(j)(l)(ii) is not required, since paragraph (k)(l)(ii) states:
We hope that this information will be helpful to you. If we can be of further assistance, feel free to contact us.
John B. Miles, Jr., Director
Directorate of Field Operations
September 9, 1985
Dear Mr. Miles:|
We recently received data from our supplier of some surfactants, containing ethylene oxide (at less than 0.001% levels) that supports an exemption under paragraph (a) (2) of 1910.1047. Thus we will maintain it in support of an exemption for our formulating plants. But we wonder if our customers are obliged to keep this data as well.
We formulate these surfactants into products in 5 to 15% weight concentrations. Certainly our supplier's data would support an exemption for our customers as well. Is it necessary for us to send this data to our customers in support of an exemption, or do they even need an exemption. It is my understanding that our label need not carry a "contains ethylene oxide" label, nor will the Material Safety Data Sheet need to indicate ethylene oxide as a hazardous ingredient, so they could conceivably never know thy were handling a product which falls under this standard.
Was the intent of this rule to regulate users of products with low levels of surfactants? Please advise.
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Diana L. Wilbur
Director of Safety
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=19408&p_text_version=FALSE