Manufactured Products & Incorrect Exemptions

By Rennee Karlik, Regulatory Compliance Specialist

It takes a special skillset and industry-specific knowledge to effectively author a safety data sheet for products that are not hazardous until subjected to further use or processing.

Additional consideration and attention to a product’s life cycle is essential to determine and communicate potential hazards and under what conditions exposure to those hazards is possible. Such products are often incorrectly identified as “articles’ that are exempt from OSHA’s Hazard Communication Standard. 

What to Consider for Exemption

Many products appear to meet the definition of an article in their manufactured form and could be accurately described as non-hazardous when they leave the manufacturing site. However, the manufacturer’s obligations do not stop at the loading dock. Consideration must be given to how the product is used and whether downstream users may be exposed to hazardous chemicals. Key to the article exemption is the requirement that under normal conditions of use, the product does release or otherwise expose workers to hazardous chemicals.

Some common examples of these products are:

  • Lumber
  • Steel
  • Welding Rods
  • Stone Countertops
  • Tile
  • Abrasive Discs 

Normal downstream activities for products like those listed do expose the users to hazardous chemicals. The first example of lumber can generate combustible dust if it is sawed, sanded or drilled into. These considerations are essential in creating an accurate and compliant safety data sheet.

What Qualifies For an Article of Exemption

GSM can provide guidance on whether your products qualify for an article exemption and help to ensure the most accurate and compliant safety data sheet. Providing users the most accurate hazard assessment saves lives and ultimately money as well.

Reach out today to speak with our experts and learn how their expertise can be leveraged for your business with TotalSDS.