The requirements for reporting safety data sheet (SDS) information under the Hazard Communication Standard

August 13, 2015

Mr. Thomas Graff
ETI Water Treatment Specialists
60 Thousand Oaks Blvd., Suite 105
Morgantown, Pennsylvania 19543

Dear Mr. Graff:

Thank you for your April 1, 2015, electronic-mail (e-mail) inquiry to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs. In your e-mail you requested confirmation on the requirements for reporting safety data sheet (SDS) information under the Hazard Communication Standard, 29 CFR 1910.1200. 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.

Question 1: In your e-mail you enclosed a safety data sheet (SDS) prepared by a supplier of a chemical used by your company. You specifically asked if OSHA allows manufacturers/suppliers to use a comma instead of a period to mark the decimal in a number on an SDS? You stated that using a comma is acceptable in European countries. For example, the supplier's SDS has a permissible exposure limit (PEL) for the chemical written as 1,4 mg/m³ instead of 1.4 mg/m³.

Response 1: As stated in your letter, it is a common understanding that the European system uses a comma instead of a period to mark a decimal in a number on an SDS. While the use of a comma between numbers on an SDS is technically incorrect in the U.S., doing so is not inconsistent with the intent of OSHA's Hazard Communication standard (HCS), 29 CFR 1910.1200. The intent of the HCS is for chemical manufacturers and importers to disseminate information on hazardous chemicals to downstream employers, and for all employers to provide such information to potentially exposed employees, and to minimize confusion about the hazards. [77 Fed. Reg. 17582, March 26, 2012] To assure there is no misunderstanding to downstream users, it is advisable for manufacturers who use the European convention to add an asterisk with a note that explains that the use of a comma in such instances is the same as a period.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA 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 any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs