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OSHA Hazard Communication Letters of Interpretation
Material Safety Data Sheet (MSDS) provisions.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Using a service does not transfer the supplier's transmission duty
This letter addresses the obsolete pre-GHS HCS before the March 11, 1994 amendments took effect. Its central principle remains consistent: a compendium or outside service can support distribution only if required sheets actually reach the downstream employer on time.
Under the current HCS, use manufacturer/importer transmission and distributor/request duties. Quarterly updates are insufficient if they miss the applicable initial or first-updated-shipment requirement. A required request cannot be dismissed as merely a private arrangement; the closing answer is expressly conditional on all HCS duties already being met. Employer immediate SDS access (FAQ) is separate. See the downstream FAQ.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
February 17, 1994
Michael B. Miller, D.D.S
Reality Publishing Company
11757 Katy Freeway, Suite 200
Houston, Texas 77079
Dear Mr. Miller:
Make your PPE readily available with safety dispensers from Safety Emporium.
Thank you for your letter of December 9, 1993 to Joseph Dear, Assistant Secretary of Labor, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) Material Safety Data Sheet (MSDS) provisions. In that letter you indicated that you are developing a compendium of MDSDs that will be distributed to all practicing dentists and that, based on a survey of manufacturers, there is a high likelihood that all manufacturers of dental products would submit MSDSs for inclusion. You inquired whether submission of MSDSs for publication in the compendium would fulfill a manufacturer's obligations under the HCS.
Section (g)(6) of the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] is most relevant to your inquiry and it states that: Chemical manufacturers or importers shall ensure that distributors and employers are provided and appropriate MSDS with their initial shipment, and with the first shipment after a material safety data sheet is updated.
OSHA included these paragraph (g) requirements in the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] to ensure that employers obtain the information necessary to inform their employees of the potential health hazards associated with using the product before those employees were exposed to the hazards.
The HCS allows flexibility for chemical manufacturers to use any method to provide MSDSs that meets the requirement of the standard. The MSDS book you describe may meet these requirements, as long as employers are provided the necessary MSDSs.
We do have some concerns about your proposal. According to the HCS the manufacturer and importer have the obligation to ensure that the MSDS are provided to the employer. The procedure that you describe appears to shift responsibility from the chemical manufacturer or importer who must provide an MSDS to the dental employer who would then have to ensure that the MSDS had been included in the book. Under the system that you propose it is likely that some dentists will not receive a new or revised MSDS at or before the time of product shipment, even if the compendium is updated quarterly. Such situation would not be in compliance with the HCS. You would have to ensure that through some mechanism MSDSs are provided to employers in a timely fashion, i.e., with their initial shipment, and with the first shipment after a material safety data sheet is updated.
You raised the following question in your letter: "even if we guarantee every dentist will receive an MSDS book with updates, they (chemical manufacturers) will still be required to send individual MSDS to dentists if requested." This is an issue between the chemical manufacturer and the MSDS requester and as long as the HCS MSDS requirements are met, it does not involve OSHA.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This answer is conditioned on all required SDS duties already being met. Current manufacturer/importer/distributor and request provisions determine when a copy must be supplied; hiring a compendium service does not transfer responsibility.]
We hope that this information will be of use to you.
Sincerely,
H. Berrien Zettler, Deputy Director
Director of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1994-02-17.