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OSHA Hazard Communication Letters of Interpretation
Requirements for labels in a language other than English.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: English label rule retained; comprehensible training is a separate duty
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard. Its narrow labeling conclusion remains consistent with current paragraph (f)(9): required English information must be present, and additional language information may be provided. Current SDSs must also be in English, with additional-language copies permitted under paragraph (g)(2).
This is not permission to train workers in a language they cannot understand. The same correspondent's April 10, 1988 follow-up explains that distinction. Apply current effective employee information and training and OSHA's training standards policy on language, vocabulary, and literacy. English labels or a signed attendance sheet alone do not establish effective training.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
February 24, 1988
Mr. Richard F. Andree
Executive Vice President
Safety & Health Management
Consultants, Inc.
161 William Street
New York, New York 10038
Dear Mr. Andree:
Your employees can stay informed and safety-ready with right to know stations and labels from Safety Emporium.
This is in response to your letter of February 1, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (29 CFR 1910.1200).
Specifically your question is, must an employer provide materials, pursuant to the Hazard Communication Standard, in a language other than English? Paragraph 29 CFR 1910.1200(f)(9) states:
(9) The employer shall ensure that labels or other forms of warning are legible, in English, prominently displayed on the container, or readily available in the work area throughout each work shift. Employers having employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well.
Thus, the employer may add information on the labels in a language other than English, but there is no requirement that they do so.
[ILPI note: Current counterpart: English label information and additional languages. This narrow label conclusion does not excuse incomprehensible training; see current training requirements and the related April 10, 1988 letter. At issuance: 1910.1200, 1987 expanded rule (PDF).]
If I may be of further assistance regarding this matter, feel free to contact me.
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/1988-02-24.