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.

October 4, 1985

L. W. Ferdinand, Manager
Loss Control Administration
Cal Gas Corporation
8401 Gerber Road
P. O. Box 28397
Sacramento, California 95828

Dear Mr. Ferdinand:

This is in response to your September 6 inquiry regarding the development of a generic Material Safety Data Sheet (MSDS) for your products. In your correspondence you asked if it would be acceptable to develop one MSDS to cover propane, butane, propylene, and butane/propane mixtures.

It is acceptable to prepare an MSDS to cover different products that contain the same chemicals in different proportions, as long as all the information required by paragraph 29 CFR 1910.1200(g) (2) is contained on the MSDS.

The generic MSDS attached to your inquiry was reviewed. Since the MSDS has information relative to chemicals in several different products, the MSDS must somehow identify the hazard information for the product that is being used.

In addition, a cursory review of the health hazard information indicates that the generic MSDS reflects one threshold limit value for the chemicals in all of the products. The MSDS must indicate the OSHA permissible exposure limit, the ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer or importer for each ingredient that has been determined to be a health hazard which is present in the product in a concentration of one percent or more (0.1 percent if a carcinogen is present). Further, the health hazard information must also be reflected on the MSDS for each chemical in the product that is determined to be a health hazard, subject to the percentage limitations mentioned above.

Finally, paragraph 29 CFR 1910.1200(g)(2)(vii) requires that the MSDS reflect whether the hazardous chemical is listed in the National toxicology Program's Annual Report on Carcinogens or has been found to be a potential carcinogen in the monographs published by the International Agency for Research or Cancer, or by OSHA.

If we may be of further assistance on this matter please let us know.


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