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 Standard Interpretations - Table of Contents

• Standard Number: 1910.1200(d)

December 1, 1988 Mr. John Thomas Cooney Plant Chemist SUS Chemical Company, Inc. Post Office Box 10027 Rock Hill, South Carolina 29731 Dear Mr. Cooney: This is in response to your letter of September 7, regarding the hazard determination requirements und er the Occupational Safety and Health Administratio n's (OSHA) Hazard Communication Standard 29 CFR 1910.12 00. Please accept by apology for the delay in respo nse. Our responses to your questions are numbered in thesequence in which they were posed. Question 1: If a company chooses not to have their products tested by this method (as stated by 29 CFR 1910.1200), what criteria would determine if a product is clas sified as corrosive on hazard warning labels and MSDS shee ts? Answer: As a chemical manufacturer, importer or employer ev aluating chemicals, you are not required to follow any specific test methods stated in 29 CFR 1910.120 0 for the hazard determination. You must, however, be able to demonstrate that the hazards of the chemic als produced or imported have been adequately ascertained in accordance with the criteria set forth in Appendix B, Hazard Determination found in 29 CFR 1910.1200. In making the hazard determination you are not required to perform chemical testing. The e valuation is to be based on currently available inf ormation. You are required to consider all availabl e scientific evidence concerning the hazard of a chem ical in addition to consulting the floor reference sources, listed in paragraph (d)(3) of the standard . These are 29 CFR Part 1910, Subpart Z, Toxic and Hazardou s Substances, OSHA; and Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment, ACGIH. Additional information sources to evaluate the hazards associated with the chemica ls are listed in Appendix C to 29 CFR 1910.1200. Question 2: Would pH measurements define corrosivity of that pr oduct or would there be other test methods? Answer: The pH is a measure of the acidity or alkalinity of a solution. Although pH is a characteristic of a c orrosive liquid, it would not define corrosivity, a s a corrosive material can be liquid or solid. Titanium tetrachlo ride is an example of a solid corrosive material. T o make a thorough and defensible hazard determinati on, not only pH but all relevant data available must be exa mined. Question 3: Should other labels such as "CAUTION IRRITANT" be u sed in place of "CORROSIVE?" Answer: An irritant is a chemical, which is not corrosive, but which causes a reversible inflammatory effect o n living tissue by chemical action at the site of c ontact. If the evidence available on a chemical indicates it is an irritant hazard rather than corrosive, the appropr iate hazard warning must be used. The hazard warnin g must convey the hazard of the chemical and the target organ effects, when such information is available (i. e., eye irritant or skin irritant). We hope this information is helpful to you. If we c an be of further assistance to you, please contact us again. Sincerely,

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# Page 1 of 2 12/01/1988

- Hazard determination criteria for corrosive liquids.

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www.OSHA.gov  Standard Interpretations - Table of Contents 

# Page 2 of 2 12/01/1988

- Hazard determination criteria for corrosive liquids.

6/ 10/2015 https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS &p_id=19724