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OSHA Hazard Communication Letters of Interpretation
Material Safety Data Sheets (MSDSs).
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Posting alone does not discharge supplier duties
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its central principle remains useful: electronic distribution can comply when the recipient has agreed and has access, while merely posting a sheet on the Internet is not a universal substitute for required transmission.
Apply supplier/distributor duties, accuracy/update requirements and immediate SDS access (FAQ). Positive update notification and reliable backup remain important. A statement about proprietary information does not authorize withholding mandatory SDS content outside the specific trade-secret provisions. See the downstream FAQ.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
November 19, 1997
Mr. Mark B. Vandenbusch
Environmental Analyst
Wisconsin Public Service Corporation
700 North Adams Street
Post Office Box 19002
Green Bay, Wisconsin 54307-9002
Dear Mr. Vandenbusch:
Thank you for your letter of August 19, in which you provided clarification to an earlier communication addressed to Congressman Jay Johnson and then forwarded to the Occupational Safety and Health Administration (OSHA) for response. In both correspondences, you have suggested that OSHA require manufacturers to post Material Safety Data Sheets (MSDSs) on the Internet and to print the Internet address for the product on the product label. You stated that this would provide a cost savings for manufacturers and would make compliance with the Hazard Communication Standard (HCS) [ILPI: Original HCS 1994 context · Current HCS] easier.
While a requirement of this nature may appear to address certain issues, the premise of our original response remains the same. That is, the HCS is performance-oriented, and as such, OSHA has avoided mandating how employers achieve compliance with the standard. Additionally, some manufacturers may consider MSDS information to be proprietary, and would not want to post this information for public access. Other manufacturers, however, have taken advantage of the Internet and use this as a vehicle for the downstream flow of hazard information. For your information, we have provided guidance, as follows, for manufacturers who use the Internet to supply MSDSs to downstream users:
- Document that customers have access to the Internet and are willing to retrieve MSDSs from this source.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. Use these conditions alongside current required transmission and update duties. Internet posting alone does not ensure receipt or immediate worker access; required information is not generally withheld merely because a supplier calls it proprietary.]
- Provide these customers with a letter giving them the Internet address of all MSDSs.
- Ensure that the most current MSDS is always available on the Internet. In the event of a significant change in health hazard information, some positive means of contact, such as a letter or e-mail notification, stating that the MSDS has changed and the updated MSDS is available would be required.
- In the event of system failure or on-line access delays, a reliable back-up for quickly receiving the required information must be available.
Many forms of electronic transmission of hazard information, such as CD-Rom, the Internet, and fax-on-demand, are available and are being used. While use of the Internet may provide a cost-savings, it is up to each manufacturer, not OSHA, to decide the best route of transmission for their hazard information.
We appreciate the time and the interest you have taken in this issue. Further questions can be directed to Maureen O'Donnell, Office of Health Compliance Assistance, (202) 219-8036, ext. 41 [corrected 12/6/2024 the Office of Health Enforcement at (202) 693-2190].
Sincerely,
Charles N. Jeffress
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1997-11-19-0.