Are pesticide manufacturers exempt from the Occupational Safety and Health Administrations (OSHA) requirement to provide a Material Safety Data Sheet (MSDS) with their product?
The hazard communications requirements of OSHA found at 29 CFR 1910.1200 include requirements for labeling and the provision of an MSDS as specified in the regulation. 29 CFR 1910.1200(b)(5)(i) specifically excludes pesticides from OSHAs labeling requirements but not the requirement to obtain or develop an MSDS as necessary under 29 CFR 1910.1200(g). See 29 CFR 1910.1200(g) or contact OSHA for specific details on when an MSDS is necessary. Nothing in the Federal Insecticide Fungicide and Rodenticide Act (FIFRA) or its implementing regulations exempts pesticide manufacturers from the hazard communications requirements of OSHA. EPA has described how MSDSs interplay with pesticide labeling in PR-Notice 92-4. More specifically, under FIFRAs definition of labeling, an MSDS that accompanies a pesticide product is labeling subject to FIFRAs misbranding provisions (see FIFRA 2(q) and 12(a)(1)) and must not conflict with EPA-approved pesticide labeling.
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