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Employee Use and Handling of Consumer Products

Lab Safety Advisor, December 20, 2005

On April 11, 2005, OSHA published a letter of interpretation that discussed the exemption of consumer products under the hazard communication standard 1910.1200 (b) (6) (ix). Laboratory safety officers tend to focus on the part of the exemption that states a material safety data sheet (MSDS) is not required for consumer or over-the-counter products such as those found in a grocery, warehouse or drug store. However, part of that section requires the employer to demonstrate that the employee uses the product as a normal consumer would.

For example, the occasional use of commercial window cleaner to clear your computer screen may not require an MSDS, but if you have an environmental services employee who works all day with window clearner, that is another matter. An MSDS for Windex would be required to maintain compliance.

OSHA states that "it is the responsibility of the employer to determine employee exposure and ascertain if the frequency of use/exposure is indeed not more than that which would be experienced by a normal consumer."

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