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|Title: 12/01/1988 - Hazard determination criteria for corrosive liquids.|
|Record Type: Interpretation||Standard Number: 1910.1200(d)|
December 1, 1988
Mr. John Thomas Cooney
SUS Chemical Company, Inc.
Post Office Box 10027
Rock Hill, South Carolina 29731
Dear Mr. Cooney:
This is in response to your letter of September 7, regarding the hazard determination requirements under the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard 29 CFR 1910.1200. Please accept by apology for the delay in response.
Our responses to your questions are numbered in the sequence in which they were posed.
Question 1: If a company chooses not to have their products tested by this method (as stated by 29 CFR 1910.1200), what criteria would determine if a product is classified as corrosive on hazard warning labels and MSDS sheets?
|Answer: As a chemical manufacturer, importer or employer evaluating chemicals, you are not required to follow any specific test methods stated in 29 CFR 1910.1200 for the hazard determination. You must, however, be able to demonstrate that the hazards of the chemicals produced or imported have been adequately ascertained in accordance with the criteria set forth in Appendix B, Hazard Determination found in 29 CFR 1910.1200. In making the hazard determination you are not required to perform chemical testing. The evaluation is to be based on currently available information. You are required to consider all available scientific evidence concerning the hazard of a chemical in addition to consulting the floor reference sources, listed in paragraph (d)(3) of the standard. These are 29 CFR Part 1910, Subpart Z, Toxic and Hazardous Substances, OSHA; and Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment, ACGIH. Additional information sources to evaluate the hazards associated with the chemicals are listed in Appendix C to 29 CFR 1910.1200.|
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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=19724&p_text_version=FALSE