08/31/2009 - Use of physical versus mailing address of the responsible party listed on the MSDS.

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Title: 08/31/2009 - Use of physical versus mailing address of the responsible party listed on the MSDS.
Record Type: InterpretationStandard 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.


    August 31, 2009

    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.

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    Question: Is a physical or mailing address required on an MSDS?

      Reply: The Hazard Communication Standard is a performance-oriented standard. This means that your company has the flexibility to comply with the standard in a way that best fits your business practices and meets the performance requirements for the standard. As you are aware, 29 CFR 1910.1200(g)(2)(xii) [in context: HCS 1994 | current regulation: HCS 2012, Appendix D as well as CPL 02-02-079, Appendix H] states:

      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.

    Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult the OSHA website at https://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

    Sincerely,

    Richard E. Fairfax, Director
    Directorate of Enforcement Programs

    The original official public domain version of this document is available from OSHA at XXXOSHAURL.