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OSHA Hazard Communication Letters of Interpretation
The requirement for single or multiple SDSs
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; current reaction-product rules are explicit
A concentrate and a diluted ready-to-use product need hazard information appropriate to their actual contents and hazards. A shared SDS is conditional on similar hazards and contents; it is not a blanket permission to merge different chemicals or kit components into one ambiguous sheet.
Current paragraph (d)(1)(ii) expressly addresses hazards from known or reasonably anticipated downstream uses and reaction products. SDS Section 10 and other relevant sections must explain pertinent reaction hazards and protective measures. See also Section 2(c) for hazards classified under (d)(1)(ii).
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
December 23, 2014
Mr. Robb Boros
Patterson Logistics Services, Inc.
1905 Lakewood Drive
Boone, Iowa 50036
Dear Mr. Boros:
Thank you for your January 17, 2014, letter to the Occupational Safety and Health Administration (OSHA), Directorate of Enforcement Programs. Your letter requested clarification on safety data sheets (SDSs) under the revised Hazard Communication standard (HCS 2012), 29 CFR 1910.1200 [ILPI: Original HCS 2012 context · Current HCS]. This letter constitutes OSHAs interpretation only of the requirements herein, and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased questions and our responses are below.
Question 1: If the end user company adds water to a concentrate solution prior to use, must the SDS for that product reflect the concentrate form of the chemical? If a company sells both concentrate and ready-to-use products, would each product require a unique SDS or would a single SDS suffice?
Response: Manufacturers or importers are required to obtain or develop a safety data sheet for each hazardous chemical that they produce. See 1910.1200(g)(1) [ILPI: Original HCS 2012 context · Current HCS]. The SDS must reflect the concentrate form of the chemical since the end user is the one that adds the water. Additionally, if the manufacturer should reasonably know that a chemical is going to be used in a particular way (e.g., if the chemical is going to be mixed with water by the downstream user), and if that use creates a new hazard, the manufacturer must disclose the hazards of reaction product in Section 10(c) of the SDS [ILPI: Original HCS 2012 context · Current HCS]. See 1910.1200(g)(2)(x) [ILPI: Original HCS 2012 context · Current HCS].
[ILPI note: At issuance: HCS 2012. Current reaction-product classification provisions, SDS Section 2(c) and Section 10 make this context explicit.]
If the concentrate chemical contains different ingredients than the ready-to-use chemical, unique SDSs must be developed for each chemical. Single SDSs are permitted only when mixtures have similar hazards and contents (i.e. the chemical ingredients are essentially the same, but the specific composition varies from mixture to mixture or batch to batch). See 1910.1200, Appendix D [ILPI: Original HCS 2012 context · Current HCS].
Question 2: If several hazardous chemicals are packaged in such a manner where each is in a separate inner container (e.g. epoxy syringe) or in a distinct compartment of a single container (e.g. amalgam capsule containing mercury and alloy powder), is an SDS required for each different hazardous chemical?
Response: Yes, a separate SDS is required for each distinct hazardous chemical. Paragraph 1910.1200(g)(1) [ILPI: Original HCS 2012 context · Current HCS] requires chemical manufacturers or importers to develop an SDS for each hazardous chemical they produce or import. Therefore, an SDS is required for each of the chemicals in the epoxy syringe and each of the chemicals in the amalgam capsule. When a manufacturer or importer intends a chemical to be used with another chemical (e.g., that two chemicals in an epoxy syringe or an amalgam capsule will be mixed together), and that use creates a new hazard, the manufacturer must also disclose the hazards of reaction products in Section 10(c) [ILPI: Original HCS 2012 context · Current HCS] (Stability and reactivity) of the SDS. OSHA would require information on the safe handling and use of the reaction product in other sections of the SDS, if different than the individual components, such as 4 (First-aid measures [ILPI: Original HCS 2012 context · Current HCS]), 5 (fire-fighting measures [ILPI: Original HCS 2012 context · Current HCS]), 6 (accidental release measures [ILPI: Original HCS 2012 context · Current HCS]), 7 (handling and storage), and 8 (exposure controls/personal protection [ILPI: Original HCS 2012 context · Current HCS]). See 1910.1200(g)(2) [ILPI: Original HCS 2012 context · Current HCS]. In the examples you provided, if there are new hazards created by the reaction of the chemicals in a syringe or amalgam capsule, this information must be included on the SDSs for each hazardous chemical.
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As you may be aware, the State of Iowa is one of 25 states plus Puerto Rico and the Virgin Islands that operates its own occupational safety and health program under a plan approved and monitored by federal OSHA. Employers in the State of Iowa must comply with state occupational safety and health requirements. As a condition of plan approval, state plans are required to adopt and enforce occupational safety and health standards that are at least as effective as those promulgated by federal OSHA. State interpretations of its standards must also be as least as effective as federal OSHA interpretations. If you would like further information regarding Iowas occupational safety and health requirements, you may contact Iowa at the following address:
Iowa Division of Labor Services
1000 East Grand Avenue
Des Moines, Iowa 50319-02209
Telephone: (515) 242-5870; Fax: (515) 281-7995
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 OSHAs 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 OSHAs website at https://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/2014-12-23.