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I know that the answer to this question will vary by country, but some aspects must be similar amongst those countries that have authorities overseeing chemical and industrial hygiene. The Wikipedia article on the topic is not so good. My understanding for the US is that a MSDS must be correct and complete to the best knowledge of the preparer of the sheet.

My question is thus:

Is there are legal requirement to the correctness and completeness (to the best of the preparer's knowledge) for a MSDS? If not, then why bother with MSDS at all?

This question was inspired by the commercial for this product from 3M. You can view the commercial by clicking on the videos link at the bottom of the site. Never mind how much nonsense their claim of "botanically pure ingredients" is, I was intrigued by the MSDS link at the top of the page. I wanted to know what the "botanically pure" substances were.

There are two versions of this product, with different scents. The MSDS for each is linked: Breeze and Lemongrass. Section 2: Ingredients lists the same four items for both products:

  • Water 65-80%
  • Cloth 20-30%
  • Sodium lauryl sulfate <3% (surfactant, not a naturally occurring substance)
  • Thyme Oil <0.1% (antibacterial, at least thymol is, and botanical in origin, but certainly not a pure substance)

No odorant is listed in the ingredients, but Section 3 clearly indicated they have different smells. 3M knows what odorant was added, and if legal requirements exist for completeness, then 3M is earning a finger-shaking and a slap on the wrist. So, again,

Is there are legal requirement to the correctness and completeness (to the best of the preparer's knowledge) for a MSDS? If not, then why bother with MSDS at all?

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OSHA's FAQ says that chemicals that make up less than 1% (0.1% if it is a carcinogen) of a product do not need to be listed on the MSDS. So it looks like 3M could be in compliance if the oderants are present in trace amounts (in that case, I have no idea why they feel the need to include the thyme oil).

The only relevant thing OSHA seems to say about consumer products specifically is that employers are not required to provide an MSDS for consumer products used in the workplace, as long as the consumer product is used in the same manner as a consumer would.

The Consumer Product Safety Commission specifically disclaims jurisdiction over chemical products, and the Chemical Safety Board doesn't appear to have anything related to consumer chemical products.

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