Frequently Asked Questions (FAQs)

Frequently Asked Questions about Data Requirements in Specs & Standards are listed below.

Data Requirements in Specs & Standards

Q: I'm developing a specification that includes hazardous materials and, thus, will require potential contractors to submit material safety data sheets. FED-STD-313, Material Safety Data, Transportation Data and Disposal Data for Hazardous Materials Furnished to Government Activities, describes how contractors are to prepare and submit material safety data sheets and, in fact, stipulates:

"Government agencies shall reference this standard in commodity specifications, contracts, and other purchase documents to assure inclusion of adequate requirements and clear instructions to contractors for the preparation and submission of Material Safety Data Sheets."

FED-STD-313 seems to be in conflict with the policy in MIL-STD-961, which states:

"Specifications shall not contain requirements for the development, preparation, acquisition of rights, submission, delivery, maintenance, updating, approval, or distribution of plans, reports, drawings, manuals, and other data products. Data can only be required in the contract. Only data product and technical manual specifications shall contain content and format requirements for data products. Data Item Descriptions (DIDs) shall not be included in any section of a technical manual specification or specification for equipments, assemblies, components, parts, materials, or any other type of commodity. Only data product specifications shall list the DIDs for which they are the source document in section 6."

How can I comply with FED-STD-313 and fulfill the requirements for material safety data sheets?

A: A specification describes a product, not the data needed to manage a program or evaluate the contractor's performance. When data (such as reports, certifications, data sheets, plans, schedules, and so forth) are necessary, they are specified as contract data requirement line items. When material safety data sheets are required, most preparing activities have chosen to provide guidance in Section 6, NOTES, of the specification, such as in the following example:

"Contracting officers will identify those activities requiring copies of completed material safety data sheets prepared in accordance with FED-STD-313. The pertinent Government mailing addresses for submission of data are listed in FED-STD-313; and 29 CFR 1910.1200 requires that the material safety data sheet for each hazardous chemical used in an operation must be readily available to personnel using the material. Contracting officers will identify the activities requiring copies of the material safety data sheet."