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.

January 30, 1997

Mr. Bernard Behrens
Export Development
Boryszew S.A.
Ul. 15 Sierpnia 106
96-500 Sochaczew POLAND

Dear Mr. Behrens:

Thank you for your inquiry regarding the information required on Material Safety Data Sheets (MSDSs). While the Occupational Safety and Health Administration (OSHA) is responsible for the content and interpretation of the Hazard Communication Standard, we do not act as a repository for MSDSs, nor do we approve MSDSs produced by manufacturers. Therefore, OSHA is not in a position to provide you with an MSDS for di-octyl phthalate for comparison purposes. We have enclosed, however, a blank MSDS which was published by OSHA and may be used as a template to help your company organize the MSDS information.

Also, enclosed is a copy of the Hazard Communication Standard, 29 CFR 1910.1200. The text of the standard begins on page 6170. Please allow me to point out that the importer of your product in the United States has responsibilities outlined in the standard and should be a source of assistance to you in this regard.

I hope that this information is helpful. Please do not hesitate to contact us if you have further questions.


Ruth McCully, Director
Office of Health Compliance Assistance

May 31, 1996

Department of Transportation (D.O.T.)
Hazardous Materials Transportation
400 7th Street, SW
Washington, DC 20590 U.S.A
tel: 001(202)426-4000

Dear Sirs/To Whom It May Concern:

I work for a chemical company in Poland which produces di-octyl phthalate, a commonly used plasticizer.

We export this chemical to manufacturers in Western Europe and North America. In order to transport this chemical, my firm must a provide a MATERIAL SAFETY DATA SHEET in English. To do so, I have translated this information from Polish to English, using a Polish Material Safety Data Sheet as the basis of my information (see copy attached).

I have written this data sheet to conform to the specifications provided to us by our clients in Western Europe. Because European material safety regulations differ from those in force in America, I would like to obtain a copy of your material safety data sheet in order to compare it to the European specifications which I use now, and to determine if I need to write another Material Safety Data Sheet to meet American requirements.

If there is any fee I must pay for a copy of the material safety data sheet promulgated by your agency, please let me know. If it would help, I am attaching a return address label for your convenience.

For your reference, the CAS number for Di-octyl phthalate, (di-2-ethyl phthalate, octyl ortho-phthalate ester) is CAS # 117-81-7.

I hope to hear from you soon.

Best regards,

Bernard Behrens
Export Development
BORYSZEW S.A. Chemical Company POLAND

(For Material Safety Data Sheet, see printed copy)