When submitting a material safety data sheet (MSDS) in order to meet the reporting requirements of EPCRA section 311, to what extent are “downstream” recipients of an MSDS, such as manufacturers and chemical users, responsible for the accuracy of the information on the MSDS, such as chemical hazard assessments?

Producers, importers, and distributers are responsible for providing accurate MSDS information; downstream recipients of an MSDS are not generally responsible for its content. However, downstream users who submit, or rely upon, MSDSs and are aware of inaccurate or inconsistent information should take reasonable steps to clarify or correct the information that they know to be inaccurate or alert the recipients of information that may be inaccurate at the time that it is distributed. (October 15, 1987, final rule (52 FR 38344; 38353 and 38359))