Standard Interpretations - Table of Contents|
| Standard Number:||1910.1200; 1910.1200(g)(2)(xi)|
April 18, 2008
Ms. Moraima Lugo-Millan
Defense Supply Center-Richmond
Hazardous Materials Information Division
8000 Jefferson Davis Highway
Richmond, VA 23297-5100
Dear Ms. Lugo-Millan,
This is in response to your correspondence dated December 11, 2007 to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. In your letter you requested clarification of the material safety data sheet (MSDS) requirements under OSHA's Hazard Communication standard (HCS), 29 CFR 1910.1200. Your paraphrased inquiry and OSHA's response follow.
Question: Some of the MSDSs maintained by our system include a statement that the information contained on the MSDS is "valid on the date of printing only." If a MSDS is printed containing the aforementioned quoted statement on one day, and then one wants to refer to the same MSDS on the next day, would the document be deemed valid on the day subsequent to printing? You specifically ask if an MSDS with the above quoted statement would be considered to be in compliance with OSHA regulations.
Answer: OSHA's hazard communication standard (HCS), 29 CFR 1910.1200(g)(2)(xi) states that MSDSs shall contain ". . .[t]he date of preparation of the material safety data sheet or the last change to it . . . " A material safety data sheet is intended to be a reference document that reflects the most accurate and current information about a specific hazardous chemical (product) that is available at the time that the MSDS is developed. It is imperative that an MSDS is a correct reflection of current scientific information related to the hazardous chemical or product, again, as of the date that the MSDS is prepared.