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.

June 30, 1986

Richard H. Schwank
President, PSP, Inc.
Peacher-Schwank Plastics, Inc.
10109 Two Notch Road
Columbia, South Carolina 29206

Dear Mr. Schwank:

President Reagan has asked the Occupational Safety and Health Administration (OSHA) to respond to your letter of May 21, concerning the application of the Hazard Communication Standard (HCS), 29 CFR 1910.1200 to Borax Powered Hand Soap.

Finished consumer products such as hand soap are exempt from the requirements of the Hazard Communication Standard. This exemption would apply as long as the product was used as it would be by a typical consumer. However, if a manufacturer purchases a product--such as cans of spray paint intended for short, one-application consumer use--and uses it in production operations, then a material safety data sheet must be provided.

The HCS is the result of over 10 years of rule-making activity. Considerable research, combined with intense public comment, have shaped the standard into what we feel is a workable and meaningful document.

We hope this information satisfies your concerns. Please feel free to contact me again if further assistance can be provided.


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