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List in SDS section 3 when the classification is based on mixture data
Dear Mr. Amoroso:
Thank you for your July 7, 2013, email to the Occupational Safety and Health Administration (OSHA). Your email was referred to OSHA's Directorate of Enforcement Programs for a response to your specific question regarding the requirement to list ingredients in Section 3 of the Safety Data Sheet (SDS) under the revised Hazard Communication standard, 29 CFR 1910.1200 (HCS 2012). This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased question and our response is below.
Scenario: A chemical manufacturer is classifying a product based on mixture test data, per 1910.1200(d)(3)(i). This data shows that although the product contains a sensitizer above the cut-off value, the mixture itself is not a sensitizer.
Question 1: For chemical mixtures classified based on whole mixture test data, do the ingredients need to be listed in Section 3 of the SDS?
Response: Yes, per 1910.1200(g)(2)(iii), all ingredients that are classified as health hazards and are present at or above their cut-off/concentration limit or present a health risk below the cut-off value/concentration limit must be listed in Section 3 of the SDS. See also 29 CFR 1910.1200, Appendix D, Safety Data Sheets, Table D.1, heading 3, for the specific content. The requirement to provide the ingredient information in Section 3 applies regardless of how the classification of the mixture is performed (i.e., whether classification is based on test data for the complete mixture, based on bridging principles, or based on cut-off values/concentration limits).
As you are aware, section A.0.4 in Appendix A, Health Hazard Criteria, of HCS 2012 provides the requirements for the classification of mixtures. Specifically, section A.0.4.1 includes the recommended order of precedence for classification. For most hazard classes, the recommended order of precedence is: (1) classification based on the test data for the complete mixture; (2) classification using bridging principles when test data are not available for the mixture itself; and (3) classification using the cut-off-values/concentration limits of the ingredients. For the hazards of Carcinogenicity, Germ Cell Mutagenicity and Reproductive Toxicity, however, mixtures must be classified based on the cut-off value/concentration limits of the mixture's ingredients, unless on a case-by-case basis, there is justification for classifying based on test data for the complete mixture.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Thomas Galassi, Director
Directorate of Enforcement Programs
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['Hazard Classifications', 'Hazcom Labeling', 'Safety Data Sheets', 'Hazard Communication']
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