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|Title: 04/14/2005 - Requirements for maintaining material safety data sheets (MSDSs) for consumer art products and office cleaning products.|
|Record Type: Interpretation||Standard Number: 1910.1200; 1910.1200(b)(6)(ix)|
April 14, 2005|
Ms. Beverly Cohen
Dear Ms. Cohen:
This is in response to your February 25, 2005, correspondence to the Occupational Safety and Health Administration (OSHA). Your letter was transferred to our Directorate of Enforcement Programs (DEP) for a response. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your letter requested clarification regarding OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200. You specifically asked about requirements for maintaining material safety data sheets (MSDSs) for consumer art products and office cleaning products.
You have referenced two different types of chemical products and asked questions related to these materials. In order to clearly answer your questions, the scenarios, and questions you presented will be paraphrased below, followed by OSHA's answers.
Question 1: The employees of my client may create visual aids and presentation displays where they would use commercial art chemical products such as thinners, adhesives, and paints. Could you please clarify whether or not the use of consumer art products by my client's employees would meet the consumer products exemption under 29 CFR 1910.1200(b)(6)(ix)?
You included different types of chemical products in your inquiry. The products in question are being used for a variety of purposes and in a variety of quantities. A consumer product that is used in a workplace in such a way that the duration and frequency of use are the same as that of a consumer is not required to be included in an employer's hazard communication program. Again, it is your client's responsibility to make this determination for his workplace by assessing the exposure potential of the consumer products he may utilize and ensuring that the frequency and duration of use of these products, by his employees, are not greater than that of normal consumer use.
Jonathan L. Snare
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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=25043&p_text_version=FALSE