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OSHA Hazard Communication Letters of Interpretation
Hazard Communication Standard (HCS) requirements.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Hazard-based coverage remains; liquid form alone does not decide exemption
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its main conclusion remains useful: physician offices must address covered hazardous chemicals, while applicable consumer and drug exemptions remain important. The final non-solid-drug summary must be read with the full conditions, not as a rule that every hazardous liquid is covered.
Under the current HCS, apply complete current drug exemption, consumer-product exemption (FAQ explanation), scope, immediate SDS access (FAQ) and current information and training requirements. Manufacturer-packaged retail and employee-personal-consumption categories can also matter. Use hazard classification and modern SDS/label requirements for nonexempt products. The enclosed 1994 rule is historical; it does not replace the current standard.
OSHA marks its matching original corrected 12/6/2024.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
March 31, 1994
The Honorable Bob Goodlatte
U.S. House of Representatives
640 Crestar Plaza
10 Franklin Road, S.E.
Roanoke, Virginia 24011
Dear Congressman Goodlatte:
Your employees can stay informed and comply with OSHA regulations with SDS information stations and compliance products from Safety Emporium.
Thank you for your letter of February 25, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) requirements. Your constituent, Dr. William F. Ball, feels that his compliance with this standard is "entirely too burdensome, unnecessary and of little benefit given the trouble and expenditure it requires."
We believe the HCS is a common sense regulation. It applies only to hazardous chemicals which are known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency. In terms of the notebooks of information mentioned by Dr. Ball, it appears that he is referring to the requirement for material safety data sheet (MSDS). The standard requires that for each hazardous chemical in the workplace, the employer is required to maintain a copy of the MSDS.
The HCS exempts several product categories, some of which would be pertinent to a physician employer. These exemptions include: any consumer product where the individual employer can show that it is used for the purpose intended by the manufacturer, and that the duration and frequency of exposure is no greater than the range of exposures experienced by consumers; drugs which are in solid, final form for direct administration to the patient (i.e., tablets or pills); drugs which are packaged by the manufacturer for sale to consumers and which employees do not administer to patients (e.g., over-the-counter medicines); and medicines which are intended for personal consumption by employees. However, non-solid, hazardous drugs are covered by the standard, and the physician employer would need to maintain a copy of the MSDS for such drugs, and include these products in the workplace hazard communication program.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. Form alone does not decide current coverage. Apply the complete current drug exemption, including retail-packaged and employee-personal-consumption categories, and actual potential exposure. Use current SDS and label requirements for nonexempt preparations.]
OSHA'S HCS provides workers exposed to hazardous chemicals with information as well as training about the identities and hazards of those chemicals, as well as protective measures. OSHA believes that when workers have such information, they are better able to take steps to protect themselves from experiencing adverse effects from exposure. In addition, providing such information to employers helps them to design better protective programs for exposed employees.
OSHA believes that significant benefits are associated with the implementation of the HCS in the workplace. Employers may use the information, for example, to select personal protective equipment, design engineering controls, and substitute less hazardous chemicals. These actions will improve protection of workers. In addition, the written information may be used to train workers to properly handle the chemical.
For further references we have enclosed copies of the booklet designed to assist employers in complying with the HCS, entitled "Chemical Hazardous Communication." We have also enclosed a copy of the current rule [ILPI: Original HCS 1994 context · Current HCS], which was updated in a February 9, 1994 Federal Register notice. The requirements of the HCS have been clarified, but not substantially changed, in this rulemaking notice.
We hope this information is helpful. If you have any further questions please contact us at (202) 219-8036.
Sincerely,
H. Berrien Zettler, Deputy Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1994-03-31-1.