That is a very good observation. That “workplace” reference is quite significant.
I interpret that to mean that if I am selling hand cleaning products distributed “solely” for use in factories and shops that no ingredient label is required under FDA regulations. That’s interesting for test marketing innovative items where I wish to keep the concepts confidential for a limited time..
Some of my products fit that definition, but others, sold in hardware stores and auto parts stores (or any place which sells to the public),do not. Even large industrial distributors (like Grainger) while selling for the workplace, are open to the public (negating the “sold solely for the workplace” exception).
That still leaves the OSHA SDS ingredient listing regulations, which certainly applies to the workplace. That “trade secret” provision I mentioned in the SDS instructions looks similar in wording to the FDA trade secret provision, but that FDA one is quite detailed that you must apply for approval to the FDA for using a trade secret exclusion and those requirements are quite stringent. I am searching to find if there is a similar OSHA provision for applying for approval to designate an ingredient as a “trade secret.”
If the SDS trade secret exception provision requirements are the same as the FDA then that’s not really an option for ingredient listing on the SDS. If that’s the case, then there are many “waterless hand cleaner” products on the market which have deceptive information sheets (as Bob seems to have observed). One main player waterless product is listing (on both label and SDS) as a primary ingredient, “microemulsion gel” with no disclosure as to what makes up that mysterious gel.
In the realm of cosmetics labeling (and especially in the hand cleaner segment) there is a lot of “what can I get away with?” thinking as opposed to “what is the right and legal thing to do?” mentality.
I am really glad that Bobzchemist broached this subject. If I have a new waterless formulation which is superior to existing market items, I want to be on a level playing field with what’s out there in reference to labeling and SDS ingredient listing requirements.
So I am very much am interested in seeing this topic explored fully