OSHA does not require that MSDSs be provided to purchasers of household consumer products when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience. This exemption in OSHA’s regulation is based, however, not upon the chemical manufacturer’s intended use of his product, but upon how it actually is used in the workplace. Employees who are required to work with hazardous chemicals in a manner that results in a duration and frequency of exposure greater than what a normal consumer would experience have a right to know about the properties of those hazardous chemicals.
Reference Interpretation and Compliance Letters:
- Provision of MSDSs for consumer products used in the workplace. [1/9/90]
- Applicability of the HCS to office workers and copy machine operators. [3/31/89]
- Application of the HCS MSDS requirements to distributors selling hazardous chemicals to consumers and employers. [5/16/90]
October 2018
Tags: HAZCOM, OSHA