Standard Interpretations - Table of Contents
• Standard Number: 1910.1200

May 7, 1993

Mr. Jere D. Kimmel
Regulatory Management Associates, Inc.
9207 Outlook Drive
Overland Park, Kansas 66207

Dear Mr. Kimmel:

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.

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. 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.

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), 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