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 4, 1990

Walter W. Allshouse, President
Supersonic Sales
Division of Massillon Supersonic
739½ Third Street, S.E.
Post Office Box 164
Massillon, Ohio 44648

Dear Mr. Allshouse:

Thank you for your letter of August 21, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200. You requested a review of your company's Material Safety Data Sheets (MSDSs) for the three Superview products: methanol, windshield washer concentrate, and windshield washer solvent.

The OSHA does not review, approve, or certify MSDSs. The HCS is a performance-oriented standard, which gives the chemical manufacturer or importer the responsibility to obtain or develop MSDSs in English that meet the following criteria and contain at least the following information: the specific identity of the hazardous chemical(s) and the common name(s); the physical and chemical characteristics of the hazardous chemical; known acute and chronic health effects and related health information; exposure limits; whether the chemical is considered to be a carcinogen by the National Toxicology Program (NTP), the International Agency for Research on Cancer (IARC), or OSHA; emergency and first-aid party procedures; precautionary measures; and the identification of the party responsible for preparing the sheet. Specific requirements are set forth in the HCS at Section (g) and Appendices A and B.

OSHA MSDS form (OSHA 174) is not a mandatory form, but may be used to comply with the HCS as long as the MSDS contains at least the above cited information. All spaces on the MSDS must be completed so the reader will know that an item has not been inadvertently omitted.

We hope the above information will assist you in your HCS compliance activities. If you would like to obtain a copy of the OSHA 174 or if further assistance is needed, you may want to contact OSHA's Regional Office in Chicago at the following address and telephone number:

 

U.S. Department of Labor - OSHA
230 South Dearborn Street, Room 3244
Chicago, Illinois 60604
Telephone: (312) 353-2220

If we can be of further assistance to you, please feel free to contact us.

Sincerely,



Patricia K. Clark
Director Designate
Directorate of Compliance Programs




August 21, 1990

Occupational Safety & Health Administration
U. S. Department of Labor
Frances Perkins Building
Third St. & Constitution Ave.
Washington, D. C. 20210

Gentlemen:

Enclosed, please find Material Safety Data Sheets for our three Superview products, Methanol, Windshield Washer Concentrate and Windshield Washer Solvent.

We request that you review these data sheets and let us know if they meet OSHA regulations, so that we may release them to our customers.

Your assistance is greatly appreciated.

Sincerely,



Walter W. Allshouse, Pres.