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 http://www.osha.gov.

August 1, 1984

Robert A. Wiesboeck, Manager
Atlanta Technical Center
USS, Agri-Chemicals,
Division of United States
Steel Corporation
685 Dekalb Industrial Way
Decatur, Georgia 30033

Dear Mr. Wiesboeck:

This is in response to your inquiry dated June 22, concerning the completion of Material Safety Data Sheets (MSDS), under the Occupational Safety and Health Administration's (OSHA) Hazard Communication standard (29 CFR 1910.1200) for products that are composed of a mixture of non-interacting chemicals.

For such products, you propose that component chemical MSDS be attached to a cover sheet identifying the mixture product and listing all constituents.

This approach is acceptable as long as the hazards associated with the mixture are not different from that of its components.

Please contact us if further assistance is needed.

Sincerely,



John B. Miles, Jr., Director
Directorate of Field Operations




June 22, 1984

Mr. John Miles
Director
Field Operations
OSHA
200 Constitution Avenue, N.W.
Room N-3603
Washington, D.C. 20210

Dear Mr. Miles:

Recently Ms. J. Silk of your office was helpful in clarifying for me a requirement of the OSHA Hazard Communication Act as it applies to mixtures.

The question was whether MSDS's for non-interacting mixtures of OSHA hazardous materials can be prepared by composing a cover sheet listing the hazardous and nonhazardous components, and attaching the manufacturers MSDS for the hazardous materials as shown on the attached sample.

It is understood that this can be done only for non-interacting materials.

Please respond to the proposal in question by letter to give me a copy for my file.

Your prompt answer is greatly appreciated.

Very truly yours,

USS AGRI-CHEMICALS



Robert A. Wiesboeck
Manager
Atlanta Technical Center