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OSHA Hazard Communication Letters of Interpretation
Generic MSDSs to cover different products that contain the same chemicals in different proportions.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Single-SDS principle retained; disclosure rules changed
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its central principle remains relevant, but current paragraph (g)(4) permits a shared SDS for complex mixtures only when their hazards and contents are similar and their ingredients are essentially the same. Merely containing the same chemicals in different proportions is not sufficient if the hazards differ. Information must clearly apply to the product in use.
A shared SDS must meet the current section structure and Appendix D content requirements. The old blanket 1%/0.1% thresholds are not a substitute for current Section 3 disclosure criteria, which can also require health-risk ingredients below a cut-off. Section 8 requires available exposure limits for ingredients or constituents listed in Section 3.
The letter's historical paragraph (g)(2)(vii) is not the current carcinogen-listing provision. The current counterpart is SDS Section 11, alongside the applicable carcinogenicity criteria. Historical citations below link to the original rule; adjacent ILPI notes identify current counterparts.
Last reviewed: .
About this ILPI assessment
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
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 https://www.osha.gov.
Source: OSHA's original letter page.
October 4, 1985
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L. W. Ferdinand, Manager
Loss Control Administration
Cal Gas Corporation
8401 Gerber Road
P. O. Box 28397
Sacramento, California 95828
Dear Mr. Ferdinand:
This is in response to your September 6 inquiry regarding the development of a generic Material Safety Data Sheet (MSDS) for your products. In your correspondence you asked if it would be acceptable to develop one MSDS to cover propane, butane, propylene, and butane/propane mixtures.
It is acceptable to prepare an MSDS to cover different products that contain the same chemicals in different proportions, as long as all the information required by paragraph 29 CFR 1910.1200(g)(2) [ILPI note: Historical citation: original 1983 rule (PDF). Current counterparts: SDS section structure, similar-mixture provision, and Appendix D.] is contained on the MSDS.
The generic MSDS attached to your inquiry was reviewed. Since the MSDS has information relative to chemicals in several different products, the MSDS must somehow identify the hazard information for the product that is being used.
[ILPI note: The current similar-mixture conditions still apply. Use Section 1 identification and product-specific information so the reader can identify which hazards apply.]
In addition, a cursory review of the health hazard information indicates that the generic MSDS reflects one threshold limit value for the chemicals in all of the products. The MSDS must indicate the OSHA permissible exposure limit, the ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer or importer for each ingredient that has been determined to be a health hazard which is present in the product in a concentration of one percent or more (0.1 percent if a carcinogen is present). Further, the health hazard information must also be reflected on the MSDS for each chemical in the product that is determined to be a health hazard, subject to the percentage limitations mentioned above.
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[ILPI note: Use current Section 3 ingredient-disclosure criteria and Section 8 exposure-limit requirements. The historical blanket 1%/0.1% rule does not cover every current disclosure obligation, including ingredients posing a health risk below a cut-off.]
Finally, paragraph 29 CFR 1910.1200(g)(2)(vii) [ILPI note: Current counterpart: Appendix D, Section 11. Current paragraph (g)(2)(vii) instead identifies Section 7, handling and storage.] requires that the MSDS reflect whether the hazardous chemical is listed in the National Toxicology Program's Annual Report On Carcinogens or has been found to be a potential carcinogen in the monographs published by the International Agency for Research or Cancer, or by OSHA.
If we may be of further assistance on this matter please let us know.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1985-10-04.