Aug 18, 1986 - Requirements for listing multiple exposure limits on MSDSs under the HCSAug 18, 1986 - Requirements for listing multiple exposure limits on MSDSs under the HCS
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Title: 08/18/1986 - Requirements for listing multiple exposure limits on MSDSs under the HCS.
It is the intent of the standard that employees and manufacturing users have a fundamental right to know the existing exposure limits of the substances with which they work. OSHA therefore encourages chemicalmanufacturers and importers to disclose all known exposure limits on the material safety data sheets.
From a compliance standpoint the material safety data sheet must contain the OSHA permissible exposure limit (PEL), and any more protective exposure limit, if one or more exists. Failure to include a less protective exposure limit, other than the OSHA PEL, will be considered a de minimis violation and will not result in the issuance of a citation.
Please feel free to contact us again if further assistance is needed.
Sincerely,
John B. Miles, Jr., Director Directorate of Field Operations
At 3M we have established a policy of placing the most conservative exposure limit and the source, i.e. ACGIH, OSHA, on the Material Safety Data Sheet. We do not customarily list all TLVs, PELs, etc. We believe this practice is prudent, since it is not confusing to those reading the MSDS and does not cloud the primary objective of clear, effective hazard communication and well-founded precautionary information. In addition, this is good practice for averting liability claims.
I understand from Mr. Gibbs that OSHA Region 5 has already adopted this policy. We would like to see acceptance of this policy in all OSHA regions. We are requesting concurrence from Federal OSHA that we are required to designate only one exposure limit which will be the most conservative.
Sincerely,
Paul W. Willard, Ph.D. Manager, Product Regulatory Toxicology Diplomat of the American Board of Toxicology
