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OSHA Hazard Communication Letters of Interpretation
Hazard determination and MSDS requirements under the Hazard Communication Standard (HCS).
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Current mixture classification and product-specific SDS duties supersede shortcuts
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Do not use its general 1%/0.1% ingredient shortcut or statement that component sheets alone satisfy every mixture SDS duty as the current rule. A mixture must be evaluated using the applicable modern health/physical criteria, not a universal concentration threshold.
Under the current HCS, hazard classification follows mixture procedures, Appendix A, and Appendix B. A required SDS must identify and accurately describe the supplied product under paragraph (g) and Appendix D; ingredient SDSs can support the evaluation without automatically replacing it.
The letter's caution about foreseeable exposure conditions remains useful. Include relevant handling and exposure-control information in Section 7/Section 8. Original Appendix B was hazard determination; current Appendix B addresses physical hazards.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 24, 1988
Mr. Jeremy Millstone
Policy Analyst
Jellinek, Schwartz, Connolly
& Freshman, Inc.
1350 New York Avenue, N.W., Suite 400
Washington, D.C. 20005
Dear Mr. Millstone
This is in response to your letter of October 3, addressed to Assistant Secretary, John A. Pendergrass, regarding hazard determination and material safety data sheet requirements under the Hazard Communication Standard (HCS) 29 CFR 1910.1200.
The HCS under 1910.1200(d)(5)(ii) allows a chemical manufacturer to assume an untested mixture to present the same health hazards as do the components which comprise one percent or greater of the mixture; or to be a carcinogenic hazard, if the mixture contains a component in concentrations of 0.1 percent or greater where the component is considered to be a carcinogen. Your client's material safety data sheet would be prepared correctly if the health hazards of the component parts greater than one percent, or 0.1 percent for any carcinogenic components, are reported.
[ILPI note: Current mixture classification uses hazard-specific rules and concentration limits in Appendix A/Appendix B. The historical 1%/0.1% shorthand is not a universal current test.]
Generally applicable control measures including engineering controls, work practices or personal protective equipment and any generally applicable precautions for safe handling and use which are known to the chemical manufacturer should also be reported on the material safety data sheet. The statement "that respiratory protection is not needed with normal use," strongly implies that there are conditions of use, emergency or otherwise, for which respiratory protection or some other control measure would be necessary; i.e., use in confined spaces, in high temperatures or with inadequate ventilation. The conditions and appropriate protective measures must be included on the material safety data sheet. Similarly, the statement that "the product is not hazardous in normal use" implies that there are no hazards associated with the product. The standard is explicit in describing the criteria to be used to determine whether or not a chemical is to be considered hazardous for purposes of the HCS. The criteria can be found in Appendix B. It is the responsibility of the chemical manufacturer, importer or employer preparing the material safety data sheet to ensure that the information recorded accurately reflects the scientific evidence used in making the hazard determination.
Where the employer chooses not to undergo a hazard determination, and is assuming a mixture has the same properties as its hazardous component parts, the data sheets for the components will satisfy the material safety data sheet requirements for the mixture.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This is not a blanket current substitute for a mixture SDS. Current counterparts: mixture classification and product SDS content. Component data may support preparation, but the supplied mixture must be accurately addressed.]
We hope this adequately responds to your concerns. If we can be of further assistance to you, please do not hesitate to contact us.
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/1988-10-24.