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OSHA Hazard Communication Letters of Interpretation
Need to supply a material safety data sheet for oil lubricated compressors.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Historical article finding is fact-specific; breathing-use statement is not an exemption
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard. An intact compressor may qualify as an article when it meets the complete current article definition, but the letter's conclusion depends on its stated no-release facts. It should not be generalized to every compressor, oil leak, servicing task, or air stream. See the SDS FAQ discussion.
A manual saying that air is unsuitable for breathing does not establish that the air has no HCS hazard. Evaluate actual pressure, composition, oil mist/other releases, and conditions of use under current hazard classification and gases-under-pressure criteria as applicable. A separately supplied hazardous lubricant or gas requires its own analysis; an equipment exemption does not automatically exempt its chemical supplies.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
November 2, 1987
James E. Lord
Kaeser Compressors, Inc.
239 Industrial Drive
P.O. Box 7416
Fredericksburg, VA 22404
Dear Mr. Lord:
This is in response to your letter to Angelo Costa of our Norfolk, VA office concerning the need to supply a material safety data sheet for oil lubricated compressors. Your letter was referred to this office for reply.
Material safety data sheets would not need to be supplied with the compressors since the compressor would be considered as an article exempted from the standard's coverage. Leakage of oil from the compressor is also not anticipated.
Since a material safety data sheet is not required for the compressor and your manuals state the compressed air is not suitable for breathing air then a material safety data sheet is not required for the compressed air mixture.
[ILPI note: The no-breathing-use statement is not a general HCS exemption. Current counterparts: complete article definition, hazard classification, and gases-under-pressure criteria as applicable. Evaluate the actual compressor, releases, and chemical supplies separately. At issuance: 1910.1200, 1987 expanded rule (PDF).]
Please contact this office if we can be of further assistance.
Sincerely,
LINDA R. ANKU
Regional Administrator
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-11-02.