not require them (see, e.g., Ex. ; Exs. 22, 25, and 30). the tennessee volunteers football crocs Many chemical manufacturers and importers are preparing MSDSs for all of their products,
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updating them more frequently to meet their internal requirements, but the rule simply requires updating when there is “significant” information of concern. Paragraph the tennessee volunteers football crocs This same commenter also said that OSHA should not permit chemical manufacturers and importers to put “worst case” recommendations on MSDSs rather than realistic recommendations (Ex. 11-50). MSDS preparers are required to provide accurate information on MSDSs. If a recommendation is not accurate, the chemical manufacturer or importer could be cited. OSHA is aware that there are MSDSs that have information on them that is not accurate in this regard. For example, the MSDS may indicate the material is not hazardous, yet under precautionary measures it is suggested that if the material gets on the skin, it must be washed off immediately.
The precautionary measures must be consistent with the hazards of the chemical, not simply written to protect the liability of the manufacturer by suggesting more protective measures than are necessary. Inclusion of SARA Title III hazard categories on the MSDSs was also suggested (Exs. 11-38, 11-52). OSHA is aware that some producers are including such information, and encourages others to do so. However, since that information is not required to protect workers, OSHA does not have the authority to require it or prohibit its being on the MSDSs. OSHA certainly cannot prevent anyone from providing MSDSs for products that are not covered by the rule. In fact, it is often useful to know that there is no hazard associated with the product, and MSDSs are often being requested so customers can assure themselves that the hazards have been evaluated. A number of commenters discussed the widespread distribution of MSDSs for products that do