OSHA Interprets Safety Data Sheet (SDS) Reporting of Petroleum Streams

Stephanie McCauley


On March 4, 2014, OSHA released a new interpretation further refining guidance of applying the 2012 Hazard Communication Standard (HCS). This time the topic was how to apply the classification and Safety Data Sheet (SDS) requirements to petroleum streams.

The problem is the contents of petroleum streams – which includes anything coming from crude oil that is either a well-defined chemical compound (butane or propane) or a substance with unknown or variable parts, complex reaction products or defined biological material – can’t be described by fixed percentages or molecular formulas because what is in them either changes or are unknown.

Therefore applying the SDS disclosure requirements to petroleum streams the same way they are done to known substances is infeasible and the following guidelines need to be followed.

  1. Provide the concentrations of groups of toxicologically similar chemicals. If it is better to treat a set of constituents as a group, and all of the toxicologically useful information can be conveyed that way, the SDS only has to have the name and concentration of the group. For example, provide the total concentration of a class of constituents like polycyclic aromatic hydrocarbons (PAH) instead of the concentration of individual PAH’s.
  2. Other chemicals known to be in the stream with classified health hazards must be listed individually in section 3 with their concentrations above the exposure limit.
  3. Where there is reliable and good information that an element of the petroleum stream poses no health risk in downstream use, it doesn’t need to be on the SDS.
  4. Concentration ranges, based on the information available (analysis result, product specifications, nature of the process) will be used when the exact concentration of a chemical or group isn’t known.  The high end of the range must not change the hazard classification.

2014 Interpretations

In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules. Here is what has been released in 2014:

  • Construction’s Electrical Power Regulations Final Rule
  • Cranes and Derricks Near Power Lines
  • Recordkeeping for Multiple Business Establishments
  • How to Decide It’s a Workplace Injury
  • Safety Data Sheet (SDS) Reporting of Petroleum Streams
  • Combustible Dust Labeling Requirements in Hazard Communication Standard (HCS)
  • OSHA Definition of A HNOC Clarified for the HCS
  • General Duty Clause Covers All Impalement Hazards
  • Employer Responsible for Determining Qualified Rigger Status
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