01/19/1989 - Letter to Paul W. Davis from Thomas Shepich concerning requirements of the HCS regarding manufacturer provision of MSDSs with first shipments of hazardous chemicals
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Title: 01/19/1989 - Letter to Paul W. Davis from Thomas Shepich concerning requirements of the HCS regarding manufacturer provision of MSDSs with first shipments of hazardouschemicals.
The HCS requires distributors to ensure that material safety data sheets (MSDS) and updated information are provided to other distributors and employers. The standard requires distributors to provide MSDS with the first shipment of hazardouschemicals to employers after September 23, 1987. Non-manufacturing employers were to be in compliance with all provisions of the standard, including having a MSDS for each hazardouschemical they use by May 23, 1988. OSHA extended the enforcement date, however, to August 1, 1988, as a result of a United States Court of Appeals decision which was unclear as to the extent of a granted stay of enforcement of the HCS. The court eventually clarified the application of the stay of enforcement only to the construction industry. Distributors were not obligated to provide MSDS during the stay. With the lifting of the stay distributors were again required to provide MSDS with next shipment of hazardouschemicals to employers on or after August 1, 1988, if a material safety data sheet had not previously been sent.
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The HCS does not prohibit distributors for asking their customers to pay for the cost of providing MSDS. The standard states that distributor shall ensure that material safety data sheets are provided to other distributors and employers. However, a distributor cannot break the established link between the requirement to provide A MSDS and the shipment of a hazardous chemical. Distributors that have shipped hazardouschemicals to downstream employers, therefore, are required to have provided the employer a MSDS. Failure of a distributor to send MSDS for hazardouschemicals previously shipped to downstream employers would result in a citation for non-compliance and abatement would require the distributor to provide the MSDS to the customers at no cost. As a result, it is the Agency's interpretation that distributors cannot charge their customers for MSDS for hazardous chemicals previously shipped. If a hazardouschemical has not yet been shipped the standard does not prohibit a distributor from charging a customer for the MSDS.
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Sincerely,
Thomas J. Shepich, Director Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at XXXOSHAURL.