Anyone can write an MSDS, so it comes from whatever hat the author pulled it out of.  There is no official review of MSDS's by any government agency.  OSHA's HazCom Standard 29 CFR 1910.1200 is performance-based, so it does not spell out explicit rules.   And the person performing the determination could potentially be incompetent or predisposed to write the hazard determination in a way that benefits them.   The fox is definitely in charge of the henhouse.

Appendix B (Mandatory) of 1910.1200 explains how the Hazard Determination is to be made.  You can view our hyperlink-enhanced version of this here: http://www.ilp i.com/msds/osha/1910_1200_APP_B.html or follow the link in the footer of the document for the plain OSHA version.

There are good sources of toxicological information for MSDS authors if your question applies to that angle.  See our MSDS FAQ question "Who can write an MSDS" at http://www.ilpi.co m/msds/faq/partc.html#whocan and http://www.osha.g ov/dsg/hazcom/recognition.html

Best regards,

Rob Toreki