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.

July 7, 1976

Mr. James E. Eads
Bloomington Manufacturing Company
1000 W. Allen Street
Bloomington, Indiana 47401

Dear Mr. Eads:

OSHA may not approve, endorse, or recommend any product or process. The word "approved" is defined in 29 CFR 1910.107(a)(8): "Shall mean approved and listed by the following nationally recognized testing laboratories: Underwriters' Laboratories, Inc.; Factory Mutual Engineering Corp."

Please find enclosed a copy of the Material Safety Data Sheet which has been used in the maritime industry for sometime. OSHA does not require use of this sheet by general industry. It has been used voluntarily by general industry, because it organizes critical data relevant to safe handling and storage.

Even if you had a product that was approved by the above definition, there are many requirements about use and handling in the general industry standards (copy enclosed). I wish to state this, because it is unclear from your letter whether or not you are familiar with those standards and how they are applied. Should you have any further questions feel free to contact me or my staff at the above address (note change), or at the toll free number 800-621-0523.

Very truly yours,

Assistant Regional Administrator
for Technical Support