| The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995! | |
| The history and philosophy behind this resource. | |
| A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics. | |
| Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term. | |
| An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more. | |
| A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers. | |
| Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet. | |
| Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources. | |
| Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors | |
| You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard | |
| Commercial suppliers of SDS authoring and management software as well as cloud compliance services. | |
| Commercial companies that will create SDS's for your specific needs as well as SDS translation companies. |
Safety signs, banners, and scoreboards? Get yours at Safety Emporium!
OSHA Hazard Communication Letters of Interpretation
Applicability of the HCS to alpha-alumina
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Evaluate current hazards; old floor-list method is superseded
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its instruction to evaluate available evidence remains relevant, but the former OSHA/ACGIH “floor” lists and one-positive-study rule do not supply the complete current classification method. An old “nuisance dust” designation is not a finding that a material is harmless.
Under the current HCS, determine hazard classification using all relevant available evidence and the applicable health/physical criteria, with an SDS where required by paragraph (g)(1). Evaluate actual form, dust, composition, and exposure; separate air-contaminant limits must also be checked. This assessment does not classify a particular present-day alumina product.
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.
April 17, 1988
R. P. Hancock, CIB
Alcan Aluminum Corporation
Post Office Box 6977
Cleveland, Ohio 44101-1977
Dear Mr. Hancock:
This is in reply to your letter of February 22, regarding the necessity of continuing to maintain a Material Safety Data Sheet (MSDS) for alpha-Alumina (Al2O3).
Alpha-Alumina is part of the floor of hazardous chemicals since the Occupational Safety and Health Administration (OSHA) regulates "nuisance dust" by 29 CFR 1910.1000 and Al2O3 is listed in Appendix D to the Threshold Limit Value (TLV) list of the latest edition of the American Conference of Governmental Industrial Hygienists (ACGIH). All substances, such as alpha-Alumina listed in Appendix D of the TLV list must be evaluated using the procedure for hazard determination outlined in 29 CFR 1910.1200(d). The company's written hazard determination is to describe the process followed, such as the sources of information consulted (OSHA, ACGIH, Registry of Toxic Effects of Chemical Substances) and the criteria used to evaluate studies. Health hazards based on at least one positive study conducted in accordance with established scientific principles and demonstrating statistically significant evidence must be listed on an MSDS.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterpart: hazard classification and the applicable health/physical criteria, rather than the superseded floor-list procedure. A historical TLV listing or the term “nuisance dust” does not by itself decide all current obligations.]
We hope this information will be helpful to you. If we can be of further assistance, please feel free to contact us again.
Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1988-04-17.