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|Title: 06/17/1986 - Application of the Hazard Communication standard to waste oils.
|Record Type: Interpretation
|Standard Number: 1910.1200
June 17, 1986
Mr. Paul Carstens
Dear Mr. Carstens:
This is in response to your letter of June 17, concerning the application of the Hazard Communication Standard (HCS), reference 29 CFR 1910.1200 to your waste oils. Please accept my apology for the delay in response.
Your letter indicates that your company is considering the production of fuel oil from waste oils regulated under the Resource Conservation and Recovery Act (RCRA) administered by the U.S. Environmental Protection Agency (EPA). The process apparently entails the addition of low flash solvents to waste oils to produce usable fuel oils.
You ask whether or not material safety data sheets (MSDS) are required for the finished fuel oil product and ask for guidance on their completion.
MSDS are required when products containing hazardous chemicals are sold to employers in the manufacturing sector [Standard Industrial Classification (SIC) codes 20-39]. Assuming your fuel oil product is destined for such an establishment and its use presents a potential for employees to be exposed to a health or physical hazard, then a MSDS is required.
The Hazard Determination provision of the HCS (reference 29 CFR 1910.1200(d) are used in conjunction with the appendices found at the end of the standard to evaluate the hazards of chemicals and chemical mixtures. Manufacturers may either test mixtures as a whole or report the effects of each of the hazardous components in a mixture. Each MSDS must accurately and thoroughly reflect the product's characteristics. Generic MSDS are permitted as long as this is accomplished.
Please feel free to contact us again if further assistance is needed.
John B. Miles, Jr., Director
Comply with state and federal regulations with hazardous waste labels fromSafety Emporium.
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June 17, 1986
Petrochem Services, Inc. is an emergency response contractor and small treatment and storage facility for hazardous waste currently operating under a part A permit from the U.S. Environmental Protection Agency. We are currently applying for our part B. One of the proposals under our part B is to accept waste or used oils (lubricating, motor, etc.), hazardous waste fuels, and waste or used solvents and to blend them into fuel oils. These fuel oils could fall into one of three categories;
I think you can appreciate the problem we are having with this. We will not be producing a product that will be highly consistent and we will be producing a product which, for all practical purposes, is nothing more than a destruction process for hazardous wastes. Furthermore, as a RCRA facility, our own employees aren't really covered by the Hazard Communication Standard, although we do inform them on the hazards of each individual waste stream.
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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=19446&p_text_version=FALSE