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|Title: 08/31/2009 - Use of physical versus mailing address of the responsible party listed on the MSDS.|
|Record Type: Interpretation||Standard Number: 1910.1200, 1910.1200(g)(2)(xii)|
ILPI Notes: This interpretation is based on and references the HCS 1994 which is now obsolete. While some parts have been deleted or changed, the conclusions of this interpretation appear consistent with the current regulation. This decision has also been referenced in a March 22, 2013 interpretation under the current regulation.
Ms. Peggy Haase
Green Environmental Consulting, Inc.
202 Vanderpool Lane
Houston, TX 77024
Dear Ms. Haase:
Thank you for your letter of July 7, 2009, to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. You requested a response for your specific question relating to the preparation of material safety data sheets (MSDSs). This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any questions not detailed within your original correspondence. Your question is paraphrased below followed by our response.
Scenario: Your incoming letter indicates that your company prepares MSDSs for a client that contracts out the blending of fuel products at several different locations and that a P.O. Box serves as a centralized location for the chemical manufacturer and, therefore, would be the best address to be included on an MSDS. You correctly noted that 29 CFR 1910.1200(g)(2)(xii) does not address the use of a mailing address versus a physical address. Additionally, you previously contacted an OSHA official, who provided you with a verbal (informal) interpretation that a mailing address alone was not sufficient.
The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary. [Emphasis added.]
Either the physical or mailing address of the party listed may be used on the MSDS. The intent of this provision in the standard is to ensure that the party listed can be reached to provide additional information on the hazardous chemicals or clarification of the information on the MSDS, as well as additional emergency procedures, if necessary. We apologize for any confusion our previous response may have caused you.
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=27206&p_text_version=FALSE