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|Title: 07/31/2008 - Requirements for labels and material safety data sheets for distributors of lumber.|
|Record Type: Interpretation||Standard Number: 1910.1200, 1910.1200(b)(6)(iv), 1910.1200(f)(2)(i)), 1910.1200(g)(7)(iii))|
|This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.|
July 31, 2008
Mr. Sean Youmans
Dakota Craft, Inc.
P.O. Box 2488
Rapid City, SD 57709
Dear Mr. Youmans:
This is in response to your letter of April 3, 2008 to U.S. Department of Labor, Occupational Safety and Health Administration (OSHA). Your letter was forwarded to Occupational Health and Safety Administration's (OSHA's) Directorate of Enforcement Programs for response. Your letter requests an interpretation of OSHA's Hazard Communication standard (HCS), 29 CFR 1910.1200. You specifically ask for information regarding OSHA's requirements for labels and material safety data sheets (MSDS) as they relate to distributors of lumber. A paraphrased description of your business operation, your questions and our responses are below.
You indicate that your company has three truss and wall manufacturing plants, three installation crews and one builder supply facility. Your inquiries relate to the building supply facility only, as you indicated that you have no questions regarding requirements of the HCS as they apply to your manufacturing and construction operations. You provided clarification to a member of my staff regarding the physical logistics of your operations. You indicated that the building supply division of your business is physically separate from the manufacturing and installation portions of your business, and the building supply division conducts retail distribution operations from a different establishment location.
Question 1: Our understanding of 29 CFR 1910.1200(g)(7)(iii) is that as a retail distributor who also has commercial accounts, we are only obligated to supply a material safety data sheet upon the request of our customer. Does OSHA agree with our understanding of that provision of the standard?
Question 2: Under 29 CFR 1910.1200(b)(6)(iv) lumber is required to be labeled in accordance with the standard where it has been treated with a hazardous chemical and/or if it may be sawed or cut as part of its downstream
use. Is that a correct statement?|
Safety Emporium has all kinds of labels for assisting with your OSHA compliance needs.
Richard E. Fairfax, Director
Directorate of Enforcement Programs
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=27400&p_text_version=FALSE