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|Title: 06/15/2011 - Requirement to name hazardous ingredients on MSDSs.|
|Record Type: Interpretation||Standard Number: 1910.1200|
|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. Note that 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 OSHA's website at http://www.osha.gov.|
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. Specifically, the reportable concentration cutoffs did not change between editions and we are unaware of any new carcinogenicity findings. However, be aware that the 2012 update changed the way that hazard determinations/classifications are made, and, more importantly, established significantly expanded guidelines for carcinogenicity determination.
June 15, 2011
One Constitution Plaza, 7th Floor
Hartford, CT 06103
Thank you for your letter requesting information on behalf of your constituent, [withheld], regarding the safety of a commercially available brand of disinfecting towelettes used in many healthcare settings. Your letter was forwarded to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs for a response. [Withheld] raised concerns that the product may be unsafe for consumer use because the hazardous ingredients listed on the manufacturer's material safety data sheet (MSDS) are inconsistent with the active ingredients listed on the product container labeling.
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=28568&p_text_version=FALSE