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Title: 06/19/2015 - Correct use of product identifiers on safety data sheets and labels
Record Type: InterpretationStandard Number: 1910.1200; 1910.1200(f)(1); 1910.1200(g)(2)(i)

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

June 19, 2015

Ms. Maureen Ruggeberg
Regulatory Affairs Specialist
Lawson Products, Inc.
8770 W. Bryn Mawr, Suite 900
Chicago, Illinois 60631-3515

Dear Ms. Ruggeberg:

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Thank you for your January 15, 2015, request to the Occupational Safety and Health Administration (OSHA) Directorate of Standards and Guidance. Your request regarding the proper use of product identifier(s) on labels and safety data sheets (SDSs)) was referred to OSHA's Directorate of Enforcement Programs for clarification of OSHA's Hazard Communication standard (HCS 2012), 29 CFR 1910.1200. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to issues not delineated within your original correspondence. Your paraphrased questions and our responses are below.

Question 1: Does the product name on a HCS 2012 label and SDS have to match word for word?

Response: Yes. HCS 2012 requires the product identifier to be included on both the label and SDS. 29 CFR 1910.1200(f)(1) and (g)(2)(i). Appendix C, C.1, Allocation of Label Elements (Mandatory) of HCS 2012 requires the label to include the product identifier used on the safety data sheet. Appendix D to HCS 2012 requires the product identifier that is used on the label to be listed in Section 1 of the SDS. Product identifier is defined as the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS. 29 CFR 1910.1200(c).

Question 2: Do product codes have to match on the HCS 2012 label and SDS?

Response: HCS 2012 requires the use of a product identifier, not a product code. If the product code(s) are being used as product identifier(s) on a label and SDS, then they must match. If product codes are being added to the label and SDS as supplemental information and the downstream user is still able to correctly cross-reference the labels and SDSs based on the product identifier, then product code(s) wouldn't necessarily have to match, as long as it does not lead to unnecessarily wide variation or undermine the required label and SDS information. Paragraph C.3.1 of Appendix C to the HCS 2012 states that the responsible party may provide additional information on a label when it provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information. Similarly, the required elements listed in Appendix D for SDSs are the minimum information required and additional information that satisfies C.3.1 may be included in the SDS.

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Question 3: If product codes or numbers are used as the product identifier on a label and SDS, do the product names have to match?

Response: Yes; see response to question 2.

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. 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.

If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs


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