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Article Exemptions for OSHA Safety Data Sheets

OSHA’s Hazard Communication Standards provide Safety Data Sheet exemptions for “articles”. Per 29 CFR 1910.1200(c) the definition of an article is:

“a manufactured item other than a fluid or particle: 

(i) which is formed to a specific shape or design during manufacture; 

(ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; and 

(iii) which under normal conditions of use does not release more than very small quantities, e.g., minute or trace amounts of a hazardous chemical, and does not pose a physical hazard or health risk to employees”

The short and simple example of an article under OSHA is a roll of copper electrical wire. The copper and insulation are: formed to a specific shape, which has an end use function that’s dependent upon the design, and does not release more than a very small quantity of any hazardous chemical. As a general rule of thumb: if an employee or professional worker is exposed to hazardous conditions associated with a product’s ingredients then the product will require an SDS

We often see article exemptions in Safety Data Sheets that don’t fit the three qualifications listed in the OSHA definition above. Article exemptions are incorrectly used for chemicals and mixtures that pose health or physical hazards which would otherwise warrant an SDS. 

Determining if your product qualifies for article exemptions needs to be performed by a professional to ensure maximum compliance with OSHA’s Safety Data Sheet requirements. Get in touch with us today to get started.

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