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OSHA Hazard Communication Letters of Interpretation
Recommendations to Increase Availability of SAVES to the Field
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Internal administrative history, not a current HazCom compliance instruction
This memorandum concerns OSHA's 1990 distribution of citation-writing material through VAX/OCIS systems. It does not establish a substantive interpretation of current employer HazCom duties, and its technology and administrative proposals should not be treated as present instructions.
For HazCom compliance, use the current HCS and current HCS inspection procedures. For current citation procedures, consult OSHA's Field Operations Manual. A citation-writing aid does not replace the applicable standard or a case-specific enforcement determination.
OSHA archive notice: OSHA marks its matching original as an archive document that may no longer represent agency policy and is retained for historical research. This notice does not by itself establish formal withdrawal.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
MAR 19 1990
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MEMORANDUM FOR: THOMAS J. SHEPICH, DIRECTOR, Office of Technical Support
PATRICIA K. CLARK, DIRECTOR DESIGNEE Directorate of Compliance Programs
FROM: LEO CAREY, DIRECTOR Office of Field Programs
SUBJECT: Recommendations to Increase Availability of SAVES to the Field
I understand that DCP is in the process of finalizing nine new sets of SAVES, which are undergoing final proofreading. These SAVES address standards in 1910.110 - 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS] and 1926.702. Based on the field's urgent and immediate need for this information, the IMIS Steering Committee has recommended to me that utilization of the VAX could save a great deal of time in the SAVES development/ publication process. I think that the committee's recommendations are worthy of serious consideration.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This is a historical internal proposal for distributing citation-writing material, not a new employer requirement. Current counterparts for compliance/enforcement context are the HCS, current HCS inspection procedures, and OSHA's Field Operations Manual.]
First, let me provide a little background to the IMIS Committee's recommendations. The Billings Area Office, as a part of the laptop pilot project, created a complete, corrected electronic version (Wordperfect/ASCII) of all of the existing SAVES that are currently resident on the Area Office microcomputers. A copy exists on the VAX which can be printed and provided to the Directorate of Compliance Programs or made available to Area Offices.
The IMIS Committee has suggested the following actions to accelerate the SAVES development/publication process:
- An electronic copy of the final corrected version of the nine sets of new SAVES be provided to Salt Lake City (SLC) to be appended to the current repository of the Billings' electronic SAVES file;
- This existing SLC SAVES file, then be added as a selection to OCIS so that it can be immediately available to the field;
- As a one-time measure, a hardcopy of the new VAX-based SAVES database be provided to DCP and to each Regional and Area Office as short-term remedy to the field's immediate need for uniform, corrected SAVES;
- Since there is now discussion about making OCIS OSHA's repository of compliance-related electronic information, the committee recommends that DCP and DTS look into the feasibility of establishing the following coordination during the SAVES development process:
- DCP provide money to an existing contract with DTS for conversion of the SAVES Committee's written draft SAVES to electronic media at SLC for subsequent review and approval;
- Changes resulting from internal OSHA reviews would be subsequently provided to SLC for electronic update;
- When the final updates have been completed, mew SAVES could be released to the field via electronic media (either by direct downloading from the VAX, or on floppy disk). Subsequent hard copies of the new SAVES could be printed locally by the Area Offices/Regional Offices/State Offices, and provided to the field staff. Notices of all changes and additions to the SAVES file would be distributed automatically to the field at the same time new SAVES are added to the OCIS SAVES file.
I welcome any thoughts you have on these recommendations or any other suggestions you have to decrease the time required to develop and publish SAVES. Please feel free to call me. I am also providing a copy of this memorandum to OMDS to keep them apprised of our discussions in this area.
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1990-03-19.