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OSHA Hazard Communication Letters of Interpretation
MSDS requirements.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Shared SDSs remain conditional; old composition and disclosure shortcuts are superseded
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its narrow generic-sheet principle remains useful: similar mixtures may share one sheet only when the applicable conditions are met. It is not permission for a single sheet covering every fertilizer or pesticide combination.
Under the current HCS, apply similar content and hazard conditions, mixture classification and ingredient identity/concentration disclosure. The old universal 1%/0.1% test and statement that amounts need not be given are not current SDS instructions. Exact concentrations or permitted ranges must follow current Section 3 rules, including applicable trade-secret provisions. Use required SDS headings and order, no-information statements, and Appendix D. EPA EPCRA reporting is separate; the constituent's proposed reporting approach is not an OSHA or EPA approval. See EPA's EPCRA resource. OSHA marks its matching source corrected December 6, 2024.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
May 7, 1993
Mr. Jere D. Kimmel
Regulatory Management Associates, Inc.
9207 Outlook Drive
Overland Park, Kansas 66207
Dear Mr. Kimmel:
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This is in response to your inquiry of April 14, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS].
Your first concern addresses the Superfund Amendments and Reauthorization Act (SARA) Title III reporting requirements, which is under the Environmental Protection Agency's (EPA) jurisdiction and can be better addressed by the EPA. You may write to your Regional EPA Office at:
EPA Region 7
726 Minnesota Avenue
Kansas City, Kansas 66115
(913) 551-7000
or call the EPA RCRA/Superfund/UST hotline at the following number: 1-800-424-9346.
Your second question addresses the suitability of a generic material safety data sheet (MSDS). As you are probably aware, the requirements for MSDSs are found in paragraph (g) of 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]. MSDSs must be developed for hazardous chemicals used in the workplace, and must list the hazardous chemicals that are found in a product in quantities of 1% or greater, or 0.1% or greater if the chemical is a carcinogen. The MSDS does not have to list the amount that the hazardous chemical occurs in the product.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This concentration-disclosure statement is obsolete. Current SDS Section 3 requires applicable ingredient identities and concentrations or permitted ranges, subject to specific exceptions. A common sheet must meet similar-mixture conditions; it does not decide EPCRA reporting.]
Therefore, a single MSDS can be developed for the various combinations of K, P and N in your fertilizer, as long as the hazards of the various fertilizer mixtures are the same. This "generic" MSDS must meet all of the minimum requirements found in 29 CFR 1910.1200(g) [ILPI: Original HCS 1987 context (PDF) · Current HCS], including the name, address and telephone number of the responsible party preparing or distributing the MSDS who can provide additional information.
We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.
Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs
April 14, 1993
Roger A. Clark
Director of Compliance Programs
US Dept. of Labor - OSHA
RM #3461
200 Constitution Ave. N.W.
Washington, D.C. 20210
Re: OSHA Instruction CPL-2-38C ILPI note: Original: CPL 2-2.38C (1990). Current: HCS inspection guidance. Oct.22, 1990 Office of Health Compliance Assistance Page A-31 (9)(4)
Dear Mr. Clark:
I am writing you at the suggestion of Glen Taylor of the Kansas City Regional OSHA office. My business, Regulatory Management Associates, Inc., provides consultation, SARA Title III reporting, MSDS Data Bank and training services involving OSHA/ Employee Right-To-Know Laws and EPA/Community Right-To-Know Laws to the Golf Course and Lawn Care industry including the Turf Chemical Distributors that supply them.
The purpose of this letter is to have a clarification of the MSDS policy toward the class of chemicals that make up fertilizer; N-Nitrogen P-Phosphorus K-Potassium (NPK). Presently, at least 80% or more of the manufacturers are providing an MSDS for each combination. This is a monumental task when you consider each ingredient usually will range from 0 to 40 in content. Depending on the weather and region of the country an average Golf/Lawn facility may have up to 20 different combinations. Multiply that by individual preferences of the managers of each of these facilities and you have almost endless possibilities.
According to the SARA Title III reporting the general TPQ of chemicals not specifically listed is 10,000 lbs. or more. This, I understand, we report by the MSDS assigned to the combination. For example: 5-10-5 - 4,000 lbs., 10-10-10 - 5,000 lbs., 0-0-40 - 6,000 lbs., 30-0-0 - 5,000 lbs., 30-20-10 - 7,000 lbs., 10-15- 20 - 8,000 lbs., 20-10-5 - 3,000 lbs., 40-0-0 - 9,000 lbs., - Total lbs. equals 47,000 lbs. There is no reportable 311 or 312 quantity since the report is based on the individual chemical as defined by the MSDS.
As you can visualize the quantity could be over 100,000 lbs. if you add the NPK combinations with pesticides that are used. I might add that most fertilizer storage areas are located near streams, lakes or storm sewers. The community and its first responders have a "Right-To-Know" so that proper planning can take place.
In addition, because of the countless combinations possible, the manufacturers have a logistical problem in supplying the required MSDS's. The problem exists at the facility of having the correct MSDS of each NPK combination.
We can resolve the problem by instructing the manufacturer to produce a generic MSDS for all NPK combinations with maybe the exception of Ammonium Nitrate and Potassium Nitrate. Without complicating matters, I would also suggest that the NPK in pesticide combinations be recognized in the same manner.
To Summarize:
- Instruct or allow manufacturers to write generic MSDS's for all NPK combinations including slow release treated.
- Instruct or allow manufacturers to write generic MSDS's for all NPK combinations with pesticides that consist of the same chemicals.
- The generic MSDS's would allow meaningful reporting under the SARA Title III laws.
Mr. Clark, I believe this situation because of its scope and potential problems needs immediate attention. Please let me know your thoughts.
Sincerely yours,
Jere D. Kimmel
President
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1993-05-07.