Clarification to the disclosure of chemical ingredients in SDS sections 3 and 8
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 28, 2020
Mr. Ranmi Aduloju
1140 63rd Street
Downers Grove, IL 60516
Dear Mr. Aduloju:
This is in response to a discussion you had with my staff regarding inconsistent information in our October 31, 2018 response to you regarding cut-off values and occupational exposure limits (OELs). Specifically, you question whether the ingredients and OELs need to be disclosed in Sections 3 and 8 of the Safety Data Sheet (SDS), in accordance with the OSHA standard, Hazard Communication, 29 CFR § 1910.1200.