OSHA Clarifies use of Concentration Ranges in SDSs

Written By: Atanu Das on Monday, October 22, 2018

During the SCHC 2018 Fall Meeting held at Arlington, VA, Sven Rundman of OSHA's Office of Health Enforcement provided an explainer on the use of concentration limits in SDSs. He highlighted a recent addition on this topic in the FAQ section on the Hazard Communication Standard.

In Section 3 of the SDS, importers and manufacturers must disclose chemical ingredient concentrations (exact percentages) if they are present in the mixture above their cut-off value or if they present a health risk below the cut-off value. Unless a trade secret claim is made, or when there is batch-to-batch variability in the production of a mixture, or for a group of substantially similar mixtures with similar chemical composition, the exact percentage must be specified. Mr. Rundman provided the following table to help further clarify when this applies:

When classifying hazards, the use of concentration ranges must be sufficiently narrow to meet the intent of disclosing the actual concentration or in cases of batches, should be an accurate representation of the expected batch variability. 

Still having questions on when to use trade secret or batch rules? Let us help.