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OSHA Hazard Communication Letters of Interpretation
Requirement for additional employee training whenever new hazards are identified.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: New-hazard training principle remains; a short meeting must still be effective
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains consistent: receipt of a new product or SDS calls for evaluation, while additional training is tied to hazards employees have not already been trained about. Covering category names once does not guarantee all future exposures are adequately addressed.
Under the current HCS, apply initial and new-hazard training and required training content. A brief safety meeting can be adequate only if it actually supplies the information and skills needed for the new hazard, protective measures, labels and SDS use. Product-specific information must remain accessible even when training is organized by hazard categories; a handout or revised SDS alone is not necessarily effective training.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
September 7, 1993
Mr. Earle Wilson
Compliance Technologies Incorporated
One Henderson
Suite 2
Box 874
Brewton, Alabama 36427
Dear Mr. Wilson:
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This is in response to your inquiry of August 11, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS].
You requested clarification of 1910.1200(h) [ILPI: Original HCS 1987 context (PDF) · Current HCS], regarding the requirement for additional employee training whenever new hazards are identified. OSHA feels that the receipt of a new MSDS or chemical compels the employer to evaluate the information provided in the MSDS to ascertain whether the new product represents a new health or physical hazard to employees. Training would have to be provided to affected employees when new hazards are introduced into the workplace (not necessarily new chemicals).
The intent of the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] training is to provide information to employees on the hazards they encounter in the workplace. Retraining can be as simple as a weekly safety meeting that highlights new chemicals in the workplace. As long as the initial training covers categories of chemicals and hazards, and how to read and understand MSDSs, retraining would merely have to assure that new products and chemicals are identified to the employees and that the hazards, if any, are recognized.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). The meeting format is an example, not a safe harbor. Current new-hazard trigger and training content still require effective instruction appropriate to actual hazards and protective measures.]
We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.
Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance
August 11, 1993
Mr. Roger A. Clark, Director
Occupational Safety and Health Administration
200 Constitution Avenue, NW
Washington, DC 20210
RE: Hazard Communication [ILPI: Original HCS 1987 context (PDF) · Current HCS] Training
REF: Federal Register, Vol. 52, No. 163, August 24, 1987, Rules and Regulations, Page 31866, Section (h) Employee Information and Training, Paragraph 2.
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Dear Mr. Clark:
It has been the generally accepted interpretation on 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS] that re-training is to occur whenever a new hazard is introduced into the workplace as evidenced by a new MSDS, a new product, or a new chemical. I'm of the opinion this is incorrect with regards to the reasons for re-training. I also feel that re-training is not required if the initial training is comprehensive and inclusive of all hazard categories.
In the above referenced Federal Register, we as trainers are given two options for training. We can train "specifically for each chemical" or we can train "regarding categories of hazards." Now, if we train based upon hazard categories and we cover all of them, is re-training ever required since the hazard can't change?
I would appreciate your reply as soon as possible.
Respectfully yours:
Earle F. Wilson President
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1993-09-07.