| 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!
| Title: 06/09/2011 - Determination of a manufactured product as an article under the Hazard Communication standard | |
| Record Type: Interpretation | Standard Number: 1910.1200 |
ILPI Notes: This interpretation is based on and references the HCS 1994 which is now obsolete. While some parts have been deleted or changed, the conclusions of this interpretation appear consistent with the current regulation. Specifically, neither the definition of "article" nor the treatment of articles has changed. However, be aware that the Standard also changed the way that hazard determinations/classifications are made.
| 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. |
June 9, 2011
Dr. Danish Jamal
Head: R&D Department
Suprabha Protective Products Pvt. Ltd.
1st Floor, Bhandari Apartment
373-Somwarpeth
Pune-411001
India
Dear Dr. Jamal:
Thank you for your October 14, 2010, letter to the Occupational Safety and Health Administration (OSHA). Your letter was referred to the Directorate of Enforcement Programs for a response. We apologize for the delay in responding to your request. You have a specific question regarding vapor corrosion inhibitor (VCI) products that your company manufactures, and the applicability of OSHA's Hazard Communication standard (HCS), 29 CFR 1910.1200 [in 2011 context: HCS 1994 | current regulation: HCS 2012] . This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any situation not delineated within your original correspondence. Your question has been paraphrased below, followed by our reply:
Question:Would VCI papers and VCI films be considered "articles" by definition under OSHA's Hazard Communication standard?
Reply: For VCI papers and films to qualify as "articles" they must satisfy the requirements specified in the definition of an article at 29 CFR 1910.1200(c) [in 2011 context: HCS 1994 | current regulation: HCS 2012] :
"Article" means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and (iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical (as determined under paragraph (d) of this section [in 2011 context: HCS 1994 | current regulation: HCS 2012]), and does not pose a physical hazard or health risk to employees.
In your letter you indicated that these products do not pose a physical hazard to workers. Further, you indicate that the chemicals used to coat or impregnate paper and films are organic, non-hazardous, and under normal conditions of use do not release more than very small quantities. However, from the information you provided, it is difficult to understand how your products will be handled by downstream workers, the chemicals that are being released, or the amount of worker exposure. This information is an important part of the hazard determination process and may help as you ascertain how the products in question should be addressed. If a manufacturer makes a reasonable determination that its product satisfies the requirements specified at 29 CFR 1910.1200(c) [in 2011 context: HCS 1994 | current regulation: HCS 2012], including that it poses no health risk or physical hazard to downstream workers, the product would then be considered an article.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 continue to consult OSHA's Web site at www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at 202-693-2190.
Sincerely,
Thomas Galassi, Director
Directorate of Enforcement Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2011-06-09.