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|Title: 12/30/1997 - Manufacturer and employer responsibilities when providing MSDSs electronically.|
|Record Type: Interpretation||Standard Number: 1910.1200; 1926.59|
December 30, 1997
The Honorable Charles S. Robb
United States Senate
Washington, DC 20510-4603
Dear Senator Robb:
Thank you for your correspondence of October 7 requesting clarification of the Hazard Communication Standard (HCS) as it pertains to the electronic transmittal of Material Safety Data Sheets (MSDSs). Specifically, you requested that OSHA issue guidelines for an acceptable format for the electronic transmission, storage, and dissemination of MSDSs.
The HCS is a performance-oriented standard, and as such, OSHA has avoided mandating any one particular format for achieving compliance with the standard. We have, however, issued general guidance for manufacturers (including importers and distributors) and employers when utilizing electronic technologies for transmission of and access to MSDSs. This guidance follows:
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Additionally, it has been a long-standing policy of OSHA that the transmission of hazard information over the phone is not acceptable. |
You also requested that OSHA re-examine our position on the liability of service companies which assist manufacturers or employers in converting MSDS information into an electronic format. These service companies are considered third-parties to the standard and are not recognized entities under the HCS. Therefore, they would not generally be cited for violations of the standard. Despite the use of third-party service providers, manufacturers maintain responsibility for the adequacy and downstream flow of hazard information and employers maintain responsibility for the adequacy of their workplace programs.
OSHA is not in a position to address the contractual obligations that third-party providers have with their clients or the responsibilities and privileges under HazCom that those obligations may confer.
It is my hope that this information is helpful. Thank you for the time and interest that you have taken in this matter. If further information is needed, please do not hesitate to contact us.
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Charles N. Jeffress
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22512&p_text_version=FALSE