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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 hazardous chemicals.
|Record Type: Interpretation
|Standard Number: 1910.1200
January 19, 1989
Mr. Paul W. Davis
Western Suppliers Association
Suite 204 1777 Borel Place
San Mateo, California 94402
Dear Mr. Davis:
This is in response to your letter of November 8, 1988, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS). Please accept my apology for the delay in response.
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 hazardous chemicals 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 hazardous chemical 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 hazardous chemicals to employers on or after August 1, 1988, if a material safety data sheet had not previously been sent.
Ensure that your MSDS collection is "readily accessible" with these handy compliance centers from Safety Emporium.
If we can be of further assistance, please feel free to contact us again.
Thomas J. Shepich, Director
Directorate of Compliance Programs
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=19739&p_text_version=FALSE