US Dept of Labor

Occupational Safety & Health AdministrationWe Can Help

Standard Interpretations - Table of Contents
• Standard Number: 1910.1200

November 16, 1994

Ms. Sheila Loftus CRASH Network 5303 Connecticut Avenue, N.W. Washington, D.C. 20015

Dear Ms. Loftus:

Thank you for your letter of May 31, concerning the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200. In that letter you request clarification for Material Safety Data Sheet (MSDS) requirements for coatings on automobile parts that will be sanded and cut. In telephone conversations with our staff, you also indicated that automobile parts are being manufactured for the express purpose of being used as replacement parts.

Manufacturers and importers are both required by the HCS to perform a hazard evaluation on the products they manufacture or import. This hazard evaluation is the responsibility of the manufacturer/importer. If, under normal conditions of use, a manufactured item meets OSHA's definition of an "article" in the standard, then the item would be exempted and an MSDS would not be required. If the hazard evaluation indicates that a product does not meet the exemption for articles, an MSDS is to be developed and transmitted to downstream employers.

The standard allows employers such as body shops to rely in good faith on the hazard evaluation performed by the manufacturer or importer. If a body shop employer is concerned because their supplier did not automatically supply an MSDS, OSHA recommends that the body shop employer contact the distributor or manufacturer/importer and verify that the manufacturer/importer has determined that no MSDS is necessary.

You also asked whether "particles in the sheet metal on parts, such as zinc," would need to be listed on the MSDS. Hazards that are associated with the processing of steel materials, such as oxide fume and dusts of zinc are to be considered hazardous by virtue of being included in the "floor" list of chemicals incorporated by reference under paragraphs (d)(3) and (d)(4) of the HCS.

We hope this information is helpful. If you have any further questions please feel free to contact the Office of Health Compliance Assistance at (202) 219-8036.

Sincerely,

Ruth McCully, Director Office of Health Compliance Assistance


Standard Interpretations - Table of Contents

Thank You for Visiting Our Website

You are exiting the Department of Labor's Web server.

The Department of Labor does not endorse, takes no responsibility for, and exercises no control over the linked organization or its views, or contents, nor does it vouch for the accuracy or accessibility of the information contained on the destination server. The Department of Labor also cannot authorize the use of copyrighted materials contained in linked Web sites. Users must request such authorization from the sponsor of the linked Web site. Thank you for visiting our site. Please click the button below to continue.

Close