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rtpzwms · July 17, 2010, 05:19 PM

with that label you might want to read this:
What agencies or regulations require us to keep MSDS's?
OSHA
The U.S. Government's Occupational Safety and Health Administration (OSHA) is responsible for the Hazard Communication Standard 29 CFR 1910.1200. The purpose of this standard is "to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training."

The Hazard Communication Standard (HCS) specifies the required elements that must be on an MSDS among other important data. It is a very readable document, and we suggest that anyone involved with MSDS management print out a hard copy for future reference.

OSHA has a suggested format for MSDS's, Form 174 (OMB #1218-0072). You can download this form in HTML format from the U.S. Department of Labor's Occupational Safety and Health Administration world wide web site if you wish. Form 174 format is not mandatory; in fact, OSHA now recommends that the ANSI format be used. An MSDS can contain more information than that required by OSHA, but not less.

EPA

Other regulations address MSDS's as well. For example, the U. S. Government's Environmental Protection Agency's (EPA) Community Right to Know Law (SARA Title III) is another set of regulations you'll want to consult.

State and Local Agencies

Many state laws may require or govern the content of MSDS's. Some of these are state Right to Know Laws. There are so many of these that we can not even begin to list them here!

If you are uncertain as to which laws apply to you, contact both your state and federal EPA and OSHA compliance (not enforcement!) offices.

Other Countries

Regulations similar to OSHA's are found in virtually every country, but these tend to vary slightly. Consult the International section of this FAQ for more information.

What is the minimum amount of material that requires an MSDS?
The HazCom standard does not specify a minimum amount, for good reason. Some chemicals are exceedingly dangerous in even milligram quantities while others are not. There is no way that the Standard could anticipate and determine the potentially toxic effects of over 50,000,000 known chemical compounds and their mixtures.
The only exception for this is when the material can release only a "very small quantities", i.e. a trace amount of hazardous chemical under normal conditions of use or a forseeable emergency. That does not mean a small amount. For example, in an OSHA Interpretation titled "Release of hazardous chemicals from gas calibration bottles", OSHA says that 2 ounces of ammonia requires an MSDS.

When trying to make a case for "trace amount", one has to consider if it is possible for an individual to be exposed to an amount of material that could cause harm. In the case above, an individual could conceivably release the contents of the cylinder into his/her face, causing harm. Likewise, the continuous release of just 25 ppm of hydrogen sulfide could cause serious harm!

Remember, OSHA does does not define something as hazardous in a particular amount.

The HCS addresses chemical hazards which are inherent properties of the hazardous chemical and would exist no matter what quantity was present in the workplace. Risk is a function of the inherent hazard and level of exposure. A substance either is or is not a hazardous chemical; the HCS definition cannot be read to indicate that a substance could be a hazardous chemical in some concentrations but not in others.

To summarize, an MSDS is required in almost every case unless there is essentially no way that the amount of material could cause harm. For additional information see this 1993 OSHA interpretation as well as this 2005 interpretation titled "Requirement to disclose all chemicals having scientific evidence that they pose a health risk regardless of concentrations present in the product on the MSDS."

Long and short of this call OSHA give them the name of the manufacturer location of manufacture and product name see what they give you.

July 17, 2010, 05:19 PM	#19
rtpzwms Senior Member Join Date: July 6, 2010 Location: OTS Posts: 1,035	with that label you might want to read this: What agencies or regulations require us to keep MSDS's? OSHA The U.S. Government's Occupational Safety and Health Administration (OSHA) is responsible for the Hazard Communication Standard 29 CFR 1910.1200. The purpose of this standard is "to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees. This transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets and employee training." The Hazard Communication Standard (HCS) specifies the required elements that must be on an MSDS among other important data. It is a very readable document, and we suggest that anyone involved with MSDS management print out a hard copy for future reference. OSHA has a suggested format for MSDS's, Form 174 (OMB #1218-0072). You can download this form in HTML format from the U.S. Department of Labor's Occupational Safety and Health Administration world wide web site if you wish. Form 174 format is not mandatory; in fact, OSHA now recommends that the ANSI format be used. An MSDS can contain more information than that required by OSHA, but not less. EPA Other regulations address MSDS's as well. For example, the U. S. Government's Environmental Protection Agency's (EPA) Community Right to Know Law (SARA Title III) is another set of regulations you'll want to consult. State and Local Agencies Many state laws may require or govern the content of MSDS's. Some of these are state Right to Know Laws. There are so many of these that we can not even begin to list them here! If you are uncertain as to which laws apply to you, contact both your state and federal EPA and OSHA compliance (not enforcement!) offices. Other Countries Regulations similar to OSHA's are found in virtually every country, but these tend to vary slightly. Consult the International section of this FAQ for more information. What is the minimum amount of material that requires an MSDS? The HazCom standard does not specify a minimum amount, for good reason. Some chemicals are exceedingly dangerous in even milligram quantities while others are not. There is no way that the Standard could anticipate and determine the potentially toxic effects of over 50,000,000 known chemical compounds and their mixtures. The only exception for this is when the material can release only a "very small quantities", i.e. a trace amount of hazardous chemical under normal conditions of use or a forseeable emergency. That does not mean a small amount. For example, in an OSHA Interpretation titled "Release of hazardous chemicals from gas calibration bottles", OSHA says that 2 ounces of ammonia requires an MSDS. When trying to make a case for "trace amount", one has to consider if it is possible for an individual to be exposed to an amount of material that could cause harm. In the case above, an individual could conceivably release the contents of the cylinder into his/her face, causing harm. Likewise, the continuous release of just 25 ppm of hydrogen sulfide could cause serious harm! Remember, OSHA does does not define something as hazardous in a particular amount. The HCS addresses chemical hazards which are inherent properties of the hazardous chemical and would exist no matter what quantity was present in the workplace. Risk is a function of the inherent hazard and level of exposure. A substance either is or is not a hazardous chemical; the HCS definition cannot be read to indicate that a substance could be a hazardous chemical in some concentrations but not in others. To summarize, an MSDS is required in almost every case unless there is essentially no way that the amount of material could cause harm. For additional information see this 1993 OSHA interpretation as well as this 2005 interpretation titled "Requirement to disclose all chemicals having scientific evidence that they pose a health risk regardless of concentrations present in the product on the MSDS." Long and short of this call OSHA give them the name of the manufacturer location of manufacture and product name see what they give you.