Article

Think of a steel bolt, a plastic toy, or a sealed battery. The chemical makeup matters less than the form. If you use the item as intended and it does not release a hazardous chemical, or only releases it in trace amounts that pose no physical or health risk, the article exemption in HazCom applies and no SDS is required.

The exemption has limits. If the item can release a chemical under normal conditions of use, such as a battery that leaks, or if the item is cut, welded, sanded, or heated in a way that creates dust or fumes, the exemption may no longer apply. A metal part is an article until you grind it, at which point the dust is a different matter.

A product that is fundamentally a chemical, even if sold in a shaped form such as a pellet or tablet, is generally treated as a Substance or Mixture instead. The test is whether the shape is the point or merely a convenient way to supply the material.

Other regulations define article differently. Under REACH, for instance, articles can still carry obligations if they intentionally release a substance or contain certain high-concern substances. Check each program's definition, not only the OSHA one.

Employers should not assume an item is exempt without thinking through how it is used and processed.