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|Title: 02/25/1993 - MSDS requirements for salt.
|Record Type: Interpretation
|Standard Number: 1910.1200(g)
February 25, 1993
The Honorable Richard G. Lugar
United States Senate
Washington, D.C. 20510
Dear Congressman Lugar:
This is in response to your letter dated January 13, to Ms. Frances McNaught of the Department of Labor. Your letter has been forwarded to the Occupational Safety and Health Administration (OSHA) for response.
A constituent of yours, Mr. Harley W. Rhodehamel, wrote to you asking why a material safety data sheet (MSDS) for salt was required by OSHA. We will explain the MSDS requirements of OSHA's Hazard Communication Standard (HCS) briefly for your constituent's benefit, and provide reasons for Sigma Chemical Company's decision to create the MSDS.
OSHA promulgated the HCS, codified as 29 CFR 1910.1200, to ensure that the hazards of all chemicals produced or imported in the U.S. are evaluated, and that information concerning their hazards is transmitted to employers and employees. The standard applies to all hazardous chemicals to which employees may be exposed under normal conditions of use or in a foreseeable emergency. The responsibility for determining whether a product is hazardous belongs to the manufacturer or importer of the chemical -- not OSHA.
Anyone working with alkali metals needs a Class D fire extinguisher such as this sodium chloride unit. Get yours from Safety Emporium.
The HCS exempts a consumer product if it meets the criteria in 29 CFR 1910.1200(b)(6)(vii), which requires that the employer demonstrate that using the consumer product would result in a "duration and frequency of exposure which is not greater than exposures experienced by consumers." In other words, when chemicals which are normally used by a consumer, such as sodium chloride, are used by employees in a manner that is not comparable to typical consumer use, the HCS requires that a hazard determination be done.
Sigma Chemical Company created the MSDS in question for places of work where sodium chloride is used in large quantities, i.e. in industrial settings. Sigma Chemical Company's MSDS provides information that is important for the employer and employee to know. Specifically, when airborne sodium chloride dust is inhaled it can cause respiratory irritation, and at high enough levels employees are to wear a respirator. Further, the MSDS warns the employer that sodium chloride is incompatible with strong oxidizing agents and strong acids, and reacts violently with bromine triflouride and lithium.
As an employer doing business in the State of Indiana, Mr. Rhodehamel may want to contact the Indiana Department of Labor. Under the Occupational Safety and Health Act of 1970, States are permitted to assume responsibility for their own occupational safety and health programs under a plan approved and closely monitored by Federal OSHA; the Indiana Department of Labor operates under such a plan. As a condition of plan approval, States are required to adopt and enforce standards that are either identical to or "at least as effective" as the Federal standards. For information regarding the requirements of Indiana standards, Mr. Rhodehamel may want to contact:
Telephone: (317) 232-2665
Roger A. Clark, Director
Directorate of Compliance Programs
June 1, 1992
The Honorable Richard G. Lugar
Senate Office Building
Washington, DC 29510
Dear Senator Lugar:
I attach a Material Safety Data Sheet for the safe handling of table salt as required by a governmental agency. One could wax sarcastically about this travesty suggesting that next we will be faced with recommendations for handling sugar or even water. Certainly, something is out of control!
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=21044&p_text_version=FALSE