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OSHA Hazard Communication Letters of Interpretation
Additional requirements for distributors from the August 24, 1987 expansion of the HCS.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Core distributor and solid-material principles generally retained
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard. Its core HazCom conclusions remain consistent: covered distributors have duties to protect their own employees, and a limited initial-shipment labeling alternative exists for specified solid materials. Apply the current HCS scope, written program, SDS access, and effective employee information and training. The May 23, 1988 deadline is historical.
Use current solid-material label provision for its exact conditions, including changed label information and the distinction between the solid material and hazardous chemicals associated with it. This is not a general once-only-label rule for every bulk shipment or for cutting fluids, lubricants, or other hazards outside that exception. Required information still follows current shipped-label elements and Appendix C. See the related May 23, 1986 scrap-dealer letter and its current comparison.
Last reviewed: .
About this ILPI assessment
This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter. This assessment reflects editorial judgment informed by human review and AI assistance. It is an opinion, may contain errors or omissions, and is not an official OSHA determination. For guidance on how OSHA requirements apply to your circumstances, contact your local OSHA office.
OSHA's notice about interpretation letters
The following notice is published on OSHA's interpretation pages; it is general guidance, not a letter-specific withdrawal notice.
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
Source: OSHA's original letter page.
October 5, 1987
Mr. Edward L. Merrigan
Attorney at Law
6000 Connecticut Avenue, N.W.
Washington, D.C. 20815
Dear Mr. Merrigan:
This is in response to your letter of September 17, requesting confirmation of previously provided interpretations of the Hazard Communication Standard, 29 CFR 1910.1200.
The interpretation previously given in our May 23, 1986 letter to you remains unaffected by the August 24, 1987 expansion of the Hazard Communication Standard. There are, however, some new employer responsibilities resulting from the expansion that I would like to apprise you of.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: written program, SDS access, training, and limited solid-material label transmission. The May 1988 deadline is historical; the solid-material alternative is not a general bulk-shipment exemption.]
Distributors, who have employees exposed to hazardous chemicals, must now maintain material safety data sheets and train their own employees. Other requirements include the development and implementation of the written hazard communication program. These duties must be met by May 23, 1988.
In addition, for a solid metal (such as a steel beam or a casting) that is not exempted as an article due to its downstream use, the expanded standard permits the required label to be transmitted to the customer at the time of the initial shipment, and need not be included with subsequent shipments to the same employer unless the information on the label changes. The label may be transmitted with the initial shipment itself, or with the material safety data sheet that is to be provided prior to or at the time of the first shipment. The exception to requiring labels on every container is only for the solid metal itself and does not apply to hazardous chemicals used in conjunction with, or known to be present with, the metal and to which employees handling the metal may be exposed (for example, cutting fluids or lubricants).
Please feel free to contact us again if further assistant is needed.
Sincerely,
John A. Pendergrass
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-10-05.