Responsibility of the employer and manufacturer to present consistent information between the labels and material safety data sheets.

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.

September 8, 2004

Mr. Michael Beckel
Supervisor of Onsite Services
3E Company
1905 Aston Avenue
Carlsbad, CA 92008

Dear Mr. Beckel:

Hazard Communication: classification of uninterruptible power source batteries and office chemicals as "consumer products."

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.

July 8, 2004

Ms. Elaine B. Enfonde
Senior Environmental Scientist
Nixon Peabody, LLP
Clinton Square
P.O. Box 31051
Rochester, New York 14603-1051

Dear Ms. Enfonde:

Requirements for manufacturers, who are no longer in business or have discontinued a product line, to provide MSDSs and product information.

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.

May 27, 2004

Mr. Robert Perkins
Technical Advisor
3E Company
1905 Aston Ave.
Carlsbad, CA 92008

Dear Mr. Perkins:

Requirement to disclose all chemicals having scientific evidence that they pose a health risk regardless of concentrations present in the product on the MSDS.

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.


April 4, 2005

Ms. Margarethe Jaroszewski, Manager
Regulatory Consulting and Applied Toxicology
Ariel Research Corp. Europe ApS
Lyngbyvej 20, 3
DK 2100 Copenhagen, Denmark

Dear Ms. Jaroszewski:

MSDS's must be provided to employees who package/process drugs for distribution into final form if they contain hazardous chemicals

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.

February 8, 2005

Ms. Monica Dahlem
Environmental, Safety and Health Consultant
107 Meadow Glen Way
Achworth, GA 30101

Dear Ms. Dahlem:

Requirements for maintaining Material Safety Data Sheets (MSDSs) for coal including coal dust, fly ash, and silica dust.

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.


April 27, 2005

John J. Frye, President
Comprehensive Safety Compliance, Inc.
295 William Pitt Way
Pittsburgh, PA 15238

Dear Mr. Frye:

Requirements for maintaining material safety data sheets (MSDSs) for consumer art products and office cleaning products.

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.

April 14, 2005

Ms. Beverly Cohen
Special Counsel
Hinman Straub Attorneys at Law
121 State Street
Albany, NY 12207-1693

Dear Ms. Cohen:

Training programs for the Control of Hazardous Energy (LOTO) and for the Hazard Communication standard are not satisfied solely by merely providing employees written documentation.

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.

October 24, 2005

Withheld

Dear Withheld:

Operations that trigger the requirement for employers to provide washing facilities on construction jobsites under 29 CFR 1926.51(f)(1).

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 12, 2006

Mr. John Schlack
648 Hemlock Court
Bensalem, PA 19020-4301

Re: Operations that trigger the requirement for employers to provide washing facilities on construction jobsites under 29 CFR 1926.51(f)(1).

Dear Mr. Schlack:

This is in response to your letter dated September 25, 2005, to the Occupational Safety and Health Administration (OSHA) regarding the requirements of 29 CFR 1926.51(f)(1). We apologize for the delay in responding.

Applicable regulations when handling waste material classified as "sludge exempt" in regards to the Hazard Communication and HAZWOPER standards.

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 23, 2005

Mr. Kenneth W. Woodlin
P.O. Box 717
Pittsburgh, PA 15230

Dear Mr. Woodlin: