Is there an MSDS exemption from the requirements for newly synthesized and uncharacterized chemicals?
Response: OSHA’s Hazard Communication Standard (HCS) 29 CFR 1910.1200 requires that manufacturers prepare and transmit MSDSs with the initial shipment of all hazardous chemicals. Research facilities which synthesize or produce chemicals are considered chemical manufacturers, if they ship hazardous chemicals, and must develop MSDSs for the hazardous chemicals that they produce and distribute to other workplaces. While the HCS is based on known information and does not require testing of chemicals in determining health effects, any relevant information which is known about the chemical or the mixture must be conveyed in the MSDS. While your laboratory may not have information concerning the precise nature of the synthesized chemicals, it is likely that your laboratory has a significant amount of important and relevant information concerning these chemical mixtures. For instance, the newly synthesized chemical would be just one component in a mixture comprised, in part, of the original re
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