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OSHA Hazard Communication Letters of Interpretation
Retraining employees who have been previously trained by another employer.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Prior training may count; 1988 nonenforcement discussion is obsolete
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its prior-training principle remains useful: an employer can use adequate training supplied by another employer, union, or association, but must ensure that employees understand their actual workplace hazards. It is not a waiver of current information and training requirements.
The OMB disapproval and May 1988 nonenforcement discussion are historical. Current multi-employer workplace provisions require methods for SDS access, precautionary measures, and labeling-system information. Construction is covered through 1926.59. Do not use this letter as a current reason to withhold coordination or hazard information.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
May 6, 1988
Mr. Blasdel A. Reardon
Chief Executive Officer
Reardon Industries, Inc.
Post Office Box 18067
Cincinnati, Ohio 45218
Dear Mr. Reardon:
This is in response to your letter dated February 26, addressed to Senator John Glenn concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard.
The Hazard Communication Standard (HCS) was first promulgated by OSHA in 1983 for the manufacturing sector. On August 24, 1987, OSHA extended the application of this rule from manufacturing industries to all industries covered by Occupational Safety and Health Act of 1970, This would include the construction industry.
The HCS affirms that employees have the right to know the hazards of the materials they work with, as well as appropriate steps they can take to protect themselves. This is to be accomplished by having a hazard communication program in each covered facility, with labels on containers of such hazardous materials, more detailed information in the form of material safety data sheets, and employee training programs.
On October 23, 1987, the Office of Management and Budget (OMB), under the authority of the Paperwork Reduction Act, made the decision to disapprove certain provisions of the expanded rule of the HCS. One of the disapproved provisions is the requirement for exchanging material safety data sheets between employers on multi-employer worksites. This is the provision referenced in your letter. As a result of the OMB decision, OSHA will not be enforcing any of the disapproved provisions on May 23, until the Agency conducts further rulemaking.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This is a historical enforcement position. Current counterpart: multi-employer workplace coordination. The training discussion remains subject to current information and training requirements and actual workplace-specific needs.]
Your employees can stay informed and comply with OSHA regulations with SDS information stations and compliance products from Safety Emporium.
OMB's disapproval of material safety data sheets at multi-employer worksites, however, does not relieve an employer's obligation to have a data sheet available for employees. Each employer would still need to ensure in some manner that material safety data sheets are available to employees when they are in their work area(s). In addition, employers would still be required to provide employees training and to ensure that containers are labeled.
Your letter also mentions the practicality of training employees who work on a limited basis. The performance nature of the standard allows employers to forego retraining employees who have been previously trained by another employer, union or other entity, if the current employer ascertains that the previous training is sufficient to meet the standard's training requirements for the current work being performed.
If I can be of further assistance, please feel free to contact me again.
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/1988-05-06.