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FAQs

Presented below, arranged according to applicability to specific sections of the ANSI 16-part MSDS, are frequently asked questions, and answers, concerning MSDSs.

Section 1. Chemical Product and Company Identification

Q: If I have a class of chemicals on the premises, which the distributor of or manufacturer of may change, must I have an MSDS from each distributor or manufacturer? For example, motor oil or gasoline is supplied to my facility by different distributors as our purchasing department changes suppliers, but it’s always motor oil or gasoline on the premises. How do the MSDS requirements apply? Can I use a generic MSDS for a class of chemicals?

Q: Is a 24-hour Emergency Number required?

Section 2. Composition and Information on Ingredients

Q: Must I disclose all components of a mixture?

Q: Must I disclose the exact composition (percentages) of the components of a mixture?

Q: Is it possible to protect component information by a claim of Proprietary Information or Trade Secret?

Section 3. Hazards Identification

Q: Is testing required to identify hazards?

Q: How does CSA perform the hazard assessment, especially for mixtures?

Section 4. First-Aid Information

Q: Employees frequently get small amounts of chemicals on their skin during routine industrial operations. Must such routine exposures be rinsed off for 15 minutes?

Q: What is the source of the 15-minute rinse recommendation?

Section 5. Fire and Explosion Hazards

Q: Why don’t the NFPA and HMIS ratings always agree?

Section 6. Accidental Release Measures

Q: Why are triple-gloves recommended for spill response?

Q: What are the levels of personal protective equipment and are these levels generally recognized?

Q: Why is LEVEL B protection recommended for initial response to a chemical spill?

Section 7. Handling and Storage

Q: If a manufacturer does not have (know) specific physical and chemical properties, must testing be performed?

Section 8. Exposure Controls - Personal Protection

Q: If a manufacturer does not have (know) specific physical and chemical properties, must testing be performed?

Section 9. Physical and Chemical Properties

Q: If a manufacturer does not have (know) specific physical and chemical properties, must testing be performed?

Section 10. Stability and Reactivity

Q: Must a manufacturer perform stability and reactivity studies of a mixture?

Section 11. Toxicological Information

Q: Must a manufacturer perform toxicological studies of a mixture?

Section 12. Ecological Information

Q: Is information required in this Section?

Section 13. Disposal Considerations

Q: Is information required in this Section?

Section 14. Transportation Information

Q: How is the Transportation Information determined for the MSDS?

Section 15. Regulatory Information

Q: Why are components listed as "on the TSCA Inventory"? What does this mean?

Q: What is the Canadian DSL?

Section 16. Other Useful Information

General Applicability

Q: Are MSDSs subject to the Record Retention Requirements of 29 CFR 1910.1020?

Section 1. Chemical Product and Company Identification

Q: If I have a class of chemicals on the premises, which the distributor of or manufacturer of may change, must I have an MSDS from each distributor or manufacturer? For example, motor oil or gasoline is supplied to my facility by different distributors as our purchasing department changes suppliers, but it’s always motor oil or gasoline on the premises. How do the MSDS requirements apply? Can I use a generic MSDS for a class of chemicals?

A: Yes, you can use a generic MSDS for a class of chemicals. If an employer chooses to use a generic MSDS, it is critical that this procedure be clearly documented in the employer’s written Hazard Communication Plan, and that employees be thoroughly trained to implement the procedure. Because of the requirement to link the product label to the MSDS, the written procedure must have a clear method of labeling the product, and the name adopted must also appear on the MSDS. Thus, the employer may choose to place a label stating MOTOR OIL on both the motor oil cans and the MSDS. The regulatory basis for this interpretation is given in the following paragraphs.

OSHA has made it very clear that the product label and the name that appears on the MSDS must be the same. For example, refer to the OSHA Inspection Procedures for the Hazard Communication Standard, CPL 2-2.38C, October 22, 1990, Appendix A. Section (f)(1). OSHA states that labels must provide a link to more detailed information available through MSDSs and other sources. Labels must contain the identity of the chemical.

OSHA has also addressed the issue of generic MSDSs for chemicals such as oils and fuels. In the same Instruction, in Appendix A, Section (g)(4), OSHA indicates that when a class of chemicals has similar health (or physical) hazards, then it is appropriate to report those hazards on a generic MSDS.

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Q: Is a 24-hour Emergency Number required?

A: Yes and no. The MSDS must have an emergency telephone number, but it does not have to be attended 24 hours per day. Actual times of availability may be listed in proximity to the emergency telephone number. Do not confuse this requirement with the US DOT requirements (49 CFR 172.201) for a 24-hour emergency number on all hazardous material shipping papers.

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Section 2. Composition and Information on Ingredients

Q: Must I disclose all components of a mixture?

A: OSHA requires that all hazardous components in excess of 1% be disclosed (addressed) on the MSDS. Carcinogens in excess of 0.1% must be disclosed. OSHA defines a hazardous chemical very broadly. According to the OSHA definition, any chemical that could possibly cause any physical or health effect under expected conditions of use or reasonably anticipated conditions of misuse are hazardous.

The following summarizes the parameters for listing a compound on the MSDS (per the regulations of the Hazard Communication Standard, 29 CFR 1910.1200, Mandatory Appendices A and B).

  • There are established exposure limits for any component of this product (specifically: TLVs®, ACGIH®; PELs, OSHA; RELs, NIOSH; MAK, DFG).
  • A component of this product is listed by the following agencies to be a potential cancer hazard: NTP, IARC, OSHA, NIOSH, or the Cal/OSHA Program.
  • A component of this product is known to be a human reproductive toxin.
  • A component of this product is on the California Proposition 65 List.
  • A component of this product has reporting requirements under SARA (Sections 302, 304, or 313) or the Clean Air Act (Section 112 (r)).
  • A component of this product is present in concentrations greater than 1 percent.

Note: The reason for this last parameter is the very broad definition of "health hazard" for chemicals (either tested or untested) in Appendices A and B of the Hazard Communication Standard. A compound is deemed to be "non-hazardous" by OSHA only if it does not produce any of the following health effects:

  • It is not a carcinogen or a potential carcinogen.
  • It is not corrosive.
  • It is not highly toxic (LD50 (oral, rat < 50 mg/kg; LD50 (skin, rabbit) < 200 mg/kg; LC50 (inhalation, rat) < 200 ppm).
  • It is not an irritant (there is a specific test for eye and skin irritancy conducted on rabbits).
  • It is not a sensitizer.
  • It is not toxic (LD50 (oral, rat) = 50-500 mg/kg; LD50 (skin, rabbit) = 200-100 mg/kg; LC50 (inhalation, rat) = 200-2000 ppm).
  • The chemical has no TARGET ORGAN EFFECTS. This includes any effect on the skin or respiratory system.

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Q: Must I disclose the exact composition (percentages) of the components of a mixture?

A: No. You can provide the composition information in terms of a range (e.g. 10–15%). It is our practice to follow the Acceptable Concentration Ranges as per CPR 11 that are provided in the Canadian Suppliers’ Guide to WHMIS on Preparing Compliant Material Safety Data Sheets and Labels.

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Q: Is it possible to protect component information by a claim of Proprietary Information or Trade Secret?

A: Yes. Under (29 CFR 1910.1200) OSHA allows claims of trade secrets and proprietary information. However, the manufacturer must abide by a variety of Federal standards on trade secrets. In addition, the manufacturer must be prepared to provide full disclosure of the composition in the event of a request from a health care provider. A number of states, such a New Jersey, Pennsylvania, and New York (to name just a few), require specific registration of the product with the state, if a trade secret claim is to be made.

Under Canadian CPR Sections 12 and 19, a supplier may request from the Hazardous Materials Information Review Commission an exemption to protect certain information (for example, specific chemical name, CAS number, and % concentration), if that information gives the company an economic advantage over competitors. A fee, which varies depending on the number of different products and the number of ingredients considered confidential, must accompany each application.

The European Union Directive 1999/45/EC of the European Parliment and of the Council of 31 May 1999 states that "Where the person responsible for placing the preparation on the market can demonstrate that the disclosure on the label or safety data sheet of the chemical identity of a substance...will put at risk the confidential nature of his intellectual property, he may, in accordance with the provisions of Annex VI, be permitted to refer to that substance either by means of a name that identifies the most important functional chemical groups or by means of an alternative name."

The Australian National Model Regulations for the Control of Workplace Hazardous Substances [NOHSC:1005(1994)] states that "The manufacturer or importer shall disclose on the MSDS for a hazardous substance the chemical name of each Type II ingredient as provided at Schedule 1, except that a generic name may be used if the identity of a Type II ingredient is commercially confidential." and "The manufacturer or importer shall disclose on the MSDS for a hazardous substance the chemical name, or alternatively a generic name may be used, for each Type III ingredient as provided at Schedule 1."

It is our practice to prepare a full-disclosure MSDS and then use it to prepare the Trade Secret version. This provides the manufacturer with all of the information needed.

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Section 3. Hazards Identification

Q: Is testing required to identify hazards?

A: OSHA does not require testing if other information is available which allows a hazard determination to be made.

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Q: How does CSA perform the hazard assessment, especially for mixtures?

A: CSA uses all of the information provided by our client, including the exact composition of the product and MSDSs for all raw materials, and adds information derived from our internal resources, including Sax Dangerous Properties of Industrial Materials and the RTECS®, among others. CSA uses all of this information to identify physical hazards and specific acute or chronic health hazards. If specific testing is needed, for example to determine a DOT Proper Shipping Name, we will advise you of this.

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Section 4. First-Aid Information

Q: Employees frequently get small amounts of chemicals on their skin during routine industrial operations. Must such routine exposures be rinsed off for 15 minutes?

A: All industrial operations should be designed to prevent all skin contact with all chemicals. However, many operations, especially those involving paints, oils, and greases, do result in skin exposure. Such exposures should be thoroughly rinsed with soapy water. Any exposure that causes any irritation or health effect must be thoroughly rinsed and the employee should seek medical attention.

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Q: What is the source of the 15-minute rinse recommendation?

A: The 15-minute minimum rinse recommendation is generally accepted throughout industry. No single original citation exists. However, widely accepted references, such as the Sigma-Aldrich Library of Chemical Safety Data (Ed. II, Robert E. Lenga, ed.), Prudent Practices for Handling Hazardous Chemicals in Laboratories (First and Second Editions, National Academy of Sciences), and Hazardous Materials Injuries (D.R. Stutz, R.C. Ricks, and M.F. Olsen) all recommend at least a 15-minute rinse that is followed by medical evaluation.

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Section 5. Fire and Explosion Hazards

Q: Why don’t the NFPA and HMIS ratings always agree?

A: The NFPA and HMIS rating systems are targeted at different audiences. They have similar appearances and similar interpretations, but they are fundamentally different. The NFPA rating system is directed at providing immediate information to firefighters responding to a fire that may involve hazardous materials. The HMIS rating system is directed toward providing persons using chemical products with general information related to safe use of the product. The NFPA rating is primarily based on flash point, LD50 (lethal dose for 50% mortality) information, and conditions firefighters may encounter. The HMIS information uses a wide variety of acute and chronic health effect parameters, as well as the same fire and reactivity parameters used by the NFPA system. Thus, ratings are frequently different.

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Section 6. Accidental Release Measures

Q: Why are triple-gloves recommended for spill response?

A: The US Coast Guard, EPA, NIOSH, and OSHA document Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities recommends inner and outer chemical protective gloves for Level A (full encapsulating, vapor-tight protection) and Level B (high level protection, which is not vapor-tight) protection. In practice, a pair of lightweight inner liners, made of an impervious material such as nitrile or latex, is typically worn under the inner chemical protective gloves. This pair of inner gloves is the last piece of protective equipment removed, prior to exit from the Decontamination Corridor. They are considered part of the inner clothing, which is not expected to become contaminated.

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Q: What are the levels of personal protective equipment and are these levels generally recognized?

A: The language associated with the four levels of personal protective equipment is specific to responses to accidental releases and to protection at EPA hazardous waste sites. The language has become standardized by all regulatory agencies as a result of the publication Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities. LEVEL A protection provides the highest level of respiratory, eye, and skin protection. LEVEL B protection provides the same level of respiratory protection but less skin protection than LEVEL A. It is generally recommended for initial site entries until the hazards have been further identified. LEVEL C protection provides the same skin protection as LEVEL B, but a lower level (air purifying respirator) of respiratory protection. LEVEL D protection is normal work clothing, which provides no respiratory protection and minimal skin protection.

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Q: Why is LEVEL B protection recommended for initial response to a chemical spill?

A: LEVEL B protection is the level of protection used as a standard throughout industry in the US when dealing with a poorly or incompletely characterized spill situation. Until such time in a spill response that the scene is fully characterized, by monitoring or in the judgement of an appropriately trained person, the protection offered by SCBA should be used. In 29 CFR 1910.120(q)(3)(iv), OSHA requires the following: Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard shall wear positive-pressure self-contained breathing apparatus while engaged in emergency response, until such time that the individual in charge of the Incident Command Center (ICS) determines through use of air monitoring that a decreased level of respiratory protection will not result in hazardous exposures to employees. Based on this language, it is our opinion that the MSDS must recommend LEVEL B protection for all but the lowest risk products.

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Section 7. Handling and Storage

Q: If a manufacturer does not have (know) specific physical and chemical properties, must testing be performed?

A: No. The MSDS can state “not available” if specific information is not known. However, providing as much information as possible is the preferred procedure for MSDS preparation.

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Section 8. Exposure Controls - Personal Protection

Q: If a manufacturer does not have (know) specific physical and chemical properties, must testing be performed?

A: No. The MSDS can state “not available” if specific information is not known. However, providing as much information as possible is the preferred procedure for MSDS preparation.

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Section 9. Physical and Chemical Properties

Q: If a manufacturer does not have (know) specific physical and chemical properties, must testing be performed?

A: No. The MSDS can state “not available” if specific information is not known. However, providing as much information as possible is the preferred procedure for MSDS preparation.

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Section 10. Stability and Reactivity

Q: Must a manufacturer perform stability and reactivity studies of a mixture?

A: No (according to OSHA). If specific stability and reactivity data are not available on the product, the MSDS can report available information for the components.

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Section 11. Toxicological Information

Q: Must a manufacturer perform toxicological studies of a mixture?

A: No (according to OSHA). If specific toxicological data are not available on the product, the MSDS can report available information for the components.

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Section 12. Ecological Information

Q: Is information required in this Section?

A: No, information is not required according to OSHA; however, if information is available for the product, or for components, it is considered a good business practice to make it available on the MSDS.

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Section 13. Disposal Considerations

Q: Is information required in this Section?

A: No, information is not required according to OSHA; however, if information is applicable for the product, or for the product, it is considered a good business practice to make it available on the MSDS.

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Section 14. Transportation Information

Q: How is the Transportation Information determined for the MSDS?

A: CSA uses the composition and hazard information from Sections 2 and 3 of the MSDS to derive an applicable Proper Shipping Name from 49 CFR 172.101. This then provides all other required information. CSA further applies the DOT regulations to address limited quantities, as applicable. CSA uses the Canadian TDG regulations for Canadian transportation information. In addition, for our clients that ship overseas, we use the current, appropriate regulations under IATA for air shipments and IMO for shipments via the sea. CSA can also provide shipping classification for shipments to or within Europe based on the classification under the ADR.

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Section 15. Regulatory Information

Q: Why are components listed as "on the TSCA Inventory"? What does this mean?

A: The TSCA Inventory is the US Government’s list of chemicals that are known to be in commerce in the United States, either by production in the US or by importation. Being on the inventory is a good thing; if a chemical compound is not on the list, there are requirements to have it registered. The MSDS for any product that contains a chemical compound as a component of the product which is not TSCA listed, must have very specific language on the MSDS to indicate this point. This is usually not a good thing as the product must be a pharmaceutical compound or its use must be limited to use in research or the direct supervision of a person who knows the hazards of that compound.

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Q: What is the Canadian DSL?

A: The Canadian DSL is the Canadian equivalent to the US TSCA Inventory. Chemicals on the DSL are known to be in commerce in Canada and were registered into the list between January 1, 1984 and December 31, 1986. There is also the Canadian NDSL. The substances on this list are based on the US TSCA Inventory for 1985. Substances on the NDSL, but not on the DSL have reporting requirements, but those requirements are not as extensive as the requirements to notify if the substance is not on either list. Being on the DSL list is also a good thing. Other national inventory lists exist for other countries and if our clients ship to a specific country, we can determine if that country has a National Chemical Inventory and indicate on the MSDS whether components have been listed in those inventories at the time of preparation of the MSDS.

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Section 16. Other Useful Information

General Applicability

Q: Are MSDSs subject to the Record Retention Requirements of 29 CFR 1910.1020?

A: OSHA gave employers two options under the record retention requirements for records of exposure data. The first and preferred option is to keep a record of the chemical(s), the time of use, and the location. The second option is to maintain a copy of the MSDS. The wording of the regulation is such that, if the second option is used, no "when" and "where" information is needed. In either case, employee exposure records must be retained for 30 years, after the employee leaves employment. This is discussed in an internal OSHA memorandum, dated December 12, 1986 from Jon Miles to Frank Strasheim. The memorandum is available on the OSHA CD-ROM.

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