The Occupational Safety and Health Administration recently responded to a letter sent by the Agricultural Retailers Association regarding the implementation of the Hazard Communication Standard (HCS) of 2012.

In June 2015, ARA, TFI, and RISE wrote to OSHA seeking clarification on how HCS will be applied to the industry's use of "custom blends." Specifically, the letter asked if custom blending is considered chemical manufacturing, and thus requires labeling and safety data sheets under HCS 2012.

The letter also asks if agricultural retailers are required to prepare new SDSs for each custom fertilizer blend, can the agricultural retailer use a single generic SDS for multiple blends; and if a generic SDS is not compliant with HCS 2012, what does OSHA recommend as guidance to accommodate custom blending operations?

OSHA's response provided answers to all three questions:

  1. Custom blending is considered chemical manufacturing, and does require individual labels and SDSs.
  2. A single generic SDS is allowed for complex mixtures with similar hazards. However, the concentration ranges used on a generic SDS must meet the intent to disclose the actual concentration range.
  3. OSHA also gave guidance that it believes including an HCS pictogram on a tanker or rail car is not in conflict with the Department of Transportation regulations.

ARA and TFI will continue to work to clarify the suitable range of components in the blends for a generic SDS. Please contact Kyle Liske if you have any questions or comments.