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OSHA Hazard Communication Letters of Interpretation
The list of hazardous chemicals are required under 1910.1200.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Product-linked inventory principle remains consistent
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its central conclusion remains consistent: the hazardous-chemical list can use a product/trade identifier linked to the SDS and label, and need not repeat every hazard classification on the list itself.
Under the current HCS, apply chemical-list requirement and product identifier. The list may cover the whole workplace or individual work areas. Its simplicity does not remove the need for accurate classification, current sheets, proper labels and current information and training requirements. A stack of sheets is not automatically a complete written program; all applicable program elements remain.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
August 5, 1994
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Mr. Doc Wallace
Safety Director
Capform, Inc.
1741 Sandy Lake Road
Post Office Box 111130
Carrollton, Texas 75011-1130
Dear Mr. Wallace:
Thank you for your letter of May 10, concerning the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS], requesting clarification on the list of hazardous chemicals as required under 1910.1200(e)(1)(i) [ILPI: Original HCS 1994 context · Current HCS], referred to in your letter as the Material Safety Data Sheets (MSDS) index sheet.
In response to your inquiry, the employer is responsible for conducting the hazardous chemical inventory and developing the list of all hazardous chemicals in the workplace by using the identity that is referenced on the MSDS and the container label. This identity is often a common name, such as a product or trade name. The HCS also requires that this list be specific to the workplace as a whole or for individual workareas. The rule does not require that you indicate the hazards of each chemical on the list; employees are informed of hazards through MSDSs, labels, and training.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. This remains consistent with current (e)(1)(i). Use product identifiers that reliably link the list to the actual SDSs and labels; detailed hazard communication still occurs through sheets, labels and training.]
In closing, please bear in mind that the HCS is a performance oriented standard. This means that the employer has the flexibility to develop a hazard communication program that best fits their workplace and also meets the performance requirements of the standard.
We hope this information is helpful. If you have any further questions please contact us at (202) 219-8036.
Sincerely,
Ruth E. McCully, Director
Office of Health Compliance Assistance
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1994-08-05.