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|Title: 04/04/2005 - Requirement to disclose all chemicals having scientific evidence that they pose a health risk regardless of concentrations present in the product on the MSDS.|
|Record Type: Interpretation||Standard Number: 1910.1200; 1910.1200(g)(2)(i)(C)(2)|
April 4, 2005|
Ms. Margarethe Jaroszewski, Manager
Dear Ms. Jaroszewski:
Thank you for your January 27, 2005, letter to the Occupational Safety and Health Administration's (OSHA's), Directorate of Enforcement Programs (DEP). Please be aware that this response may not be applicable to any statement or question not delineated within your original correspondence. You had specific questions regarding OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200, as it applies to material safety data sheets (MSDSs) for mixtures. Your statement and question are paraphrased below, followed by our response.
Statement: We are in the process of developing Material Safety Data Sheets (MSDSs) for our European clients who are exporting their products to the United States. During the process several questions arose regarding 29 CFR 1910.1200(g)(2)(i)(C)(2); which states " The chemical and common names(s)...which comprise less than 1% (0.1% for carcinogens) of the mixture, if there is evidence that the ingredient(s) could be released from the mixture in concentrations which would exceed an established OSHA Permissible Exposure Limit or ACGIH Threshold Limit Value, or could present a health risk to employees;". Our clients are faced with a situation where many of their cosmetic products used by beauticians and hairdressers contain small amounts (below 0.1%) of fragrance or preservatives that are recognized skin sensitizers.
Question: What is the existing practice for lower limits of disclosure, and what are the requirements for our clients to be in compliance?
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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=25079&p_text_version=FALSE