Are MSDSs Required for Consumer Chemical Products?

Just back from the American Society of Safety Engineers (ASSE) show in San Antonio.  Great show and thanks to all that stopped by our booth.  A number of people at the show asked me if material safety data sheets (MSDSs) are required for consumer products like Windex or Lysol?

This is a common question we receive; especially now, with companies focusing more on safety and compliance in response to OSHA ramping up its regulatory enforcement efforts.

In general, the OSHA Hazard Communication Standard (HCS) requires businesses to have Material Safety Data Sheets (MSDSs) for all potentially  hazardous chemicals present at a work site.  But the answer more accurately lies in how your employees use these types of products at your workplace.

Essentially, if your employees use consumer chemical products in the same manner that any other consumer would, and as directed by the manufacturer, you probably don’t need to worry about having an MSDS.

On the contrary, however, if your employees use consumer chemical products for purposes that extend beyond that of an average consumer, especially in regards to the frequency and quantity of use, then their exposure rate is higher and you most likely do need to supply MSDSs for those products.

Here are a couple of real-world use scenarios:

Scenario 1: An employee  uses a disinfectant spray to clean off a desk or work area once or twice a day. This squarely falls into the "as directed by the manufacturer," camp and would constitute a consumer use of that product. Therefore, you would not be required to provide an MSDS.

Scenario 2: The employee uses the same disinfectant spray in a health care setting to continually clean and disinfect numerous surfaces throughout the workday.  In this case, the frequency of use would likely constitute non-consumer use of the product.  Therefore, you would be required to incorporate that product into your HCS program and provide the appropriate MSDS and training for your employees.

When thinking about this, let common sense be your compass.  And, as we tell our customers, better safe than sorry... there's no penalty for erring on the side of caution.  If you're unsure, better to simply have the MSDS.

For more information on this topic, we recommend reading the OSHA Letter of Interpretation titled, “Requirements for maintaining material safety data sheets (MSDSs) for consumer art products and office cleaning products.”

We hope this helps.  If you have other questions regarding your MSDS compliance requirements, let us know.

– Glenn Trout, President, MSDSonline

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