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OSHA Hazard Communication Letters of Interpretation
Establishment of a Centralized Telephone Information Service for hazardous Waste/HCS Inquiries
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Administrative history; this memo does not create employer obligations
This internal OSHA memorandum, since removed from the agency's website, proposed a centralized telephone-information service for hazardous-waste, emergency-response and HazCom inquiries. It appears that the proposed hotline was never established. The memo requests workload data from OSHA offices; it does not create employer obligations or require employers to answer the attached questionnaire.
Use the current HCS for HazCom duties and OSHA's current office directory for assistance. The separate public-worker hazardous-waste provision is EPA 40 CFR Part 311; it does not extend every federal OSHA standard to every public employer.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 general notice about interpretation letters
The following general notice is illustrated by a different OSHA letter. That example is not the source of this memorandum, and the notice is 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.
September 27, 1990
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MEMORANDUM FOR: REGIONAL ADMINISTRATORS
THROUGH: LEO CAREY, DIRECTOR, OFFICE OF FIELD PROGRAMS
FROM: PATRICIA K. CLARK DIRECTOR DESIGNATE DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Establishment of a Centralized Telephone Information Service for hazardous Waste/HCS Inquiries
This is to request information on the need for a centralized telephone information service to assist Regions, Area Offices, States, and the general public with inquiries about hazardous waste, emergency response and hazard communication issues.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This is an internal workload survey and proposal with a historical October 15, 1990 deadline, not a present employer requirement. Current assistance: OSHA office directory; public-worker hazardous-waste context: 40 CFR Part 311.]
Under Congressional mandate the Environmental Protection Agency (EPA) issued a worker protection standard equivalent to 29 CFR 1910.120 [ILPI: Original 1989 HAZWOPER context (PDF) · Current HAZWOPER] in order to cover public workers in States without OSHA State plans. EPA is looking to OSHA to take the lead on setting policies and interpretations on the worker protection standard and will reimburse OSHA for this activity.
Presently, the Office of Health Compliance Assistance is overburdened with inquiries on these standards and therefore, is developing plans to utilize available EPA Superfund monies to supply additional OSHA resources to address these issues. If there is sufficient need, it may be possible to establish a national information service to respond to all inquiries pertaining to hazardous waste, emergency response and hazard communication. Before we can move forward with this proposal, we need to have a clearer understanding of the Agency workload currently involved with responding to inquiries related to these issues.
I ask that each of you query your Area Offices and State Programs and obtain the necessary information to complete the attached questionnaire. Since we would like to begin a pilot of this project early next fiscal year, it is important that we receive your responses, including your States' responses, to these questions by close of business, October 15, 1990. Should you have questions concerning these issues, contact MaryAnn Garrahan of my staff at FTS 523-8036. Our fax number is FTS 523-9187.
OSHA HOTLINE QUESTIONNAIRE
- Approximately how many telephone and/or written inquiries does your office receive on a monthly basis relating to hazardous waste, emergency response and hazard communication issues?
- Hazardous Waste
- Telephone _______
Written _______
Congressionals _______
FOIA's _______
Other written _______
- Hazardous Waste
- Emergency Response
- Telephone _______
Written _______
Congressionals _______
FOIA's _______
Other written _______ - Hazard Communications
- Telephone _______
Written _______
Congressionals _______
FOIA's _______
Other written _______ - Do you feel that the establishment of an OSHA Hotline to respond to telephone callers and written requests would free up your staff for other projects? YES ______ NO ______ (explain)
- Do you feel that a toll free OSHA hotline would be beneficial? YES ______ NO ______ (explain)
Other Comments are Welcome:
Submitted by: ______________________ Telephone Number: _____________________
This internal OSHA memorandum has been removed from OSHA's website. An archived copy of the original is available through the Wayback Machine.