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.

October 9, 1987

MEMORANDUM FOR:  REGIONAL ADMINISTRATORS

THRU:            LEO CAREY, DIRECTOR
                 DIRECTORATE OF FIELD OPERATIONS

FROM:            THOMAS SHEPICH, DIRECTOR
                 DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:         Clarification of Material Safety Data Sheet
                 Requirements Under the Hazard Communication Standard.

The following clarification relates to the Material Safety Data Sheet (MSDS) requirements of the Hazard Communication Standard (HCS), reference 29 CFR 1910.1200.

Paragraph (g)(3) of the standard requires that chemical manufacturers, importers and employers preparing a MSDS include explanatory statements in blank sections. Accordingly, preparers must mark blank sections with any words that convey the idea that the information was not applicable or not available.

The duty imposed under paragraph (g)(3) of the HCS has raised the question of whether a preparer can simply exclude a block from the MSDS rather than making an explanatory note?

Based on an interpretive reading of the standard, blocks or sections may be omitted in their entirety if no information is available or non-existent.

If you have any question regarding this clarification, please contact Roy Gibbs or Steve Simon on FTS 523-8036.