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.

September 3, 1993

Mr. Andrew Marmaduke,

Regional Environmental Specialist
Safety-Kleen
2727 Paces Ferry Road 2 Paces West,
Suite 1660
Atlanta, Georgia 30339

Dear Mr. Marmaduke:

This is in response to your letter of July 22, and to a telephone conversation with Mr. Ron Davies of my staff, in which you requested a written confirmation from the Occupational Safety and Health Administration (OSHA) that a particular solvent is correctly classified as a combustible liquid on the basis of the information found in the Material Safety Data Sheet (MSDS) attached to your incoming letter.

With reference to 29 CFR 1910.1200(d) of the Hazard Communication Standard, employers may rely on the information included on a MSDS required by 29 CFR 1910.1200(g) to determine workplace compliance with OSHA safety and health standards. A product, identified as such on the corresponding MSDS, may be considered a combustible, unless known otherwise by the employer, for example, through his or her evaluation.

If we can be of further assistance, please feel free to contact James C. Dillard of my staff, at (202) 219-8031.

Sincerely,



Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance