| The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995! | |
| The history and philosophy behind this resource. | |
| A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics. | |
| Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term. | |
| An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more. | |
| A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers. | |
| Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet. | |
| Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources. | |
| Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors | |
| You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard | |
| Commercial suppliers of SDS authoring and management software as well as cloud compliance services. | |
| Commercial companies that will create SDS's for your specific needs as well as SDS translation companies. |
Safety signs, banners, and scoreboards? Get yours at Safety Emporium!
OSHA Hazard Communication Letters of Interpretation
Employers are responsible for training new employees on the HCS
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Prior training may count; current employer remains responsible
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains consistent: training can come from another organization, but the current employer must determine whether it meets the employee's actual needs and correct any gaps.
Under the current HCS, current information and training requirements apply at initial assignment and whenever a new chemical hazard is introduced. Prior general training does not replace instruction on the workplace's specific hazards, protective measures, labels, and SDS access. Training must be understandable; see OSHA's language, vocabulary, and literacy policy.
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 11, 1988
Mr. Frank L. Pellegrini
Suite 400 Chouteau Center
133 South Eleventh Street
St. Louis, MO 63102
Dear Mr. Pellegrini:
Ensure your workers are trained with safety posters and more at Safety Emporium.
This is in response to your letter of January 6, to Mr. Denver Holt, Area Director or our St. Louis Area Office, concerning the Occupational Safety and Health Administration (OSHA) August 24, 1987, expanded rule for the Hazard Communication Standard (HCS).
Specifically you asked "whether a contractor's association can train union hall employees and qualify for training under the hazard communication rule," or "whether each contractor must train each employee coming to them from a union hall, irrespective or the associations." As you mentioned in your letter each employer is responsible for training under the Hazard Communication Standard. The standard, however, does not require that each new employee be trained.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This does not exempt newly assigned employees from effective information and training. Current counterpart: current information and training requirements. Credit adequate prior instruction, then address any new hazards and workplace-specific gaps.]
The HCS is a performance-oriented standard and the goal of the training provisions is to ensure that employees are trained according to those provisions. It is OSHA's position, therefore, that training can be provided by the current employer, a past employer, an employee union, or any other entity. From an enforcement standpoint OSHA field personnel will evaluate an employer's compliance with the training and information provisions of the HCS. If it is determined that an employee has not received training or is not adequately trained the current employer will be held responsible regardless of who trained that particular employee. An employer, therefore, has a responsibility when hiring a new employee, who has been previously trained by someone other than the current employer to evaluate the employee's level of knowledge against the training and information requirements of the standard.
If I can be of further assistance, please feel free to contact me again.
Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1988-05-11.