Product Labels and Material Safety Data Sheets (MSDS)

OSHA's Hazard Communication and formaldehyde standard require formaldehyde and other substances that can lead to formaldehyde exposure to be listed in two places for products: on the label on the product bottle or box and in the product's material safety data sheets (MSDSs)/safety data sheets (SDSs), which are documents that explain the health hazards of products that contain hazardous chemicals and the recommended safe practices for working with them. Knowing how to read and understand labels and MSDSs/SDSs is important to protecting worker health.

If a product contains 0.1% or more formaldehyde or releases at least 0.1ppm to 0.5ppm of it into the air, then the label must include:

• Notice that the product contains formaldehyde.
• Name and address of the manufacturer, importer, and/or other responsible party.
• Notice that physical and health hazards of the product are readily available from the employer and in the SDS.

If the product can release more than 0.5ppm of formaldehyde into the air, then the label must also include:

• A list of all product health and safety hazards.
• The words "Potential Cancer Hazard" may be used prior to June 1, 2015.
  • After June 1, 2015 the words "May cause cancer" must be used.

OSHA recently updated the hazard communications standard. MSDSs will now be called SDSs and both may be used until June 1, 2015. After June 1, 2015 only SDSs will be accepted. SDSs will generally list the same information as MSDSs, but all information will now be presented in a common format detailed in 29 CFR 1910.1200 Appendix D [Mandatory]. The MSDS/SDS for all hair products as well as any other hazardous products used in the salon must be available to all workers. MSDSs/SDSs must have the following information:

• Product Identification (Section 1, Identification, on SDS):
  • The name of the product used on the label or product identifier.
  • The name, address and telephone number of the chemical manufacturer, importer or other responsible party.
• Products Hazards, which include a description of the physical and health hazards of the product (Section 2, Hazard Identification, on SDS).
• Composition (Section 3, Composition/information on ingredients, on SDS):
  • Chemical name, common name and synonyms of all hazardous chemicals that make up 1% or more of the product.
  • Chemical name, common name and synonyms of all ingredients that can cause cancer (such as formaldehyde, if present) and make up 0.1% or more of the product.
  • Chemical name, common name and synonyms of all hazardous chemicals that can be released into the air at levels that would pose a health risk for employees (for example, 0.1 ppm for formaldehyde).
• First aid (Section 4, First Aid Measures, on SDS).
• Fire-fighting measures (Section 5, Fire-fighting measures on SDSs).
• Emergency Procedures, which explain what to do in an emergency (Section 6, Accidental Release Measure, on SDS).
• Safe storage and use (Section 7, Handling and Storage, on SDS).
• Protective measures (such as proper ventilation and protective equipment) and exposure limits (Section 8, Exposure Controls/Personal Protection, on SDS):
  • Exposure limits adopted by OSHA; or determined by the American Conference of Governmental Industrial Hygienists (ACGIH), Threshold Limit Value (TLV).
  • Any other exposure limit used or recommended by the chemical manufacturer or importer.
• Properties of the product (e.g., solid, liquid, solubility, vapor pressure, etc.) (Section 9, Physical and chemical properties, on SDS).
• Chemicals to avoid, conditions to avoid, etc. (Section 10, Stability and Reactivity, on SDS).
• Health Effects (Section 11, Toxicological information, on SDS):
  • Common ways by which people may be exposed to the product and its hazardous ingredients.
  • Notice of whether the chemical is considered a cancer causing (carcinogen) substance: listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest edition) or by OSHA
• Date of preparation, or revision (Section 16, Other information, on SDS).

Please note that OSHA mandates that the headers for Sections 12-15 be present but is not enforcing the contents of these sections.

Chemicals that Can Release Formaldehyde

Just because the name "formaldehyde" or the name methylene glycol is not on a product label or MSDS does not mean the product cannot expose workers to formaldehyde. Sometimes, manufacturers or distributors intentionally omit ingredients from labels or MSDS. There are also other names for formaldehyde, and other chemicals that can expose you to formaldehyde when the product is used. These are listed in the table below, and are subject to the same OSHA rules as formaldehyde.

Chemicals That Can Release Formaldehyde¹