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OSHA Hazard Communication Letters of Interpretation
MSDS should be distributed for welding wire containing hazardous chemicals.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; welding-wire hazards still require communication
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its central HazCom conclusion remains consistent with the current HCS: hazardous welding wire and hazards generated in its use require evaluation and hazard communication. Under current paragraph (d)(1), consider the material's form and reaction products associated with known or reasonably anticipated uses, including welding fumes.
Apply the current article definition before claiming an exemption; welding wire is not automatically exempt because it is a solid manufactured item. See SDS preparation and possession, distribution, and employee access. The office address and telephone below are historical; use the current OSHA office directory for present inquiries.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 14, 1986
Mr. A. H. Krieg
President
Widder Corporation
Great Hill Road
Post Office Box 1069
Naugatuck, Connecticut 06770-1069
Dear Mr. Krieg:
Senator Lowell Weicker, Jr., has asked the Occupational Safety and Health Administration (OSHA) to respond to your letter of December 30, 1985, to him.
Keep informed about workplace hazards with proper labeling techniques and safety posters available from Safety Emporium.
Promulgation of the Hazard Communication Standard (HCS) on November 25, 1983, was the culmination of over 10 years of rulemaking activity by OSHA. The standard is based on the premise that employees have a right to know the identities and hazards of the substances to which they may be exposed in their place of employment. This knowledge will ultimately result in a reduction in the occurrence of illnesses and injuries resulting from such exposures.
The major vehicle for informing employees about the hazardous substances to which they may be exposed to is the Material Safety Data Sheet (MSDS). These are written documents that provide extensive information on the chemical identification of components, as well as other useful information such as the hazards of the chemicals and protective measures. MSDS are required for each hazardous chemical in the workplace.
The MSDS for the welding wire that you produce clearly indicates that it contains hazardous chemicals that could affect the health of employees who use it. By providing a MSDS for the welding wire employees will be in a better position to protect themselves from any potential hazards associated with its use.
[ILPI note: Current counterparts: classification for the material and hazards generated in use and SDS distribution.]
If you have additional questions regarding the HCS or other OSHA regulations, please feel free to contact our Area Office in Hartford:
Area Director
U.S. Department of Labor - OSHA
Federal Office Building, Room 508
450 Main Street
Hartford, Connecticut 06103
Telephone: (203) 244-2294
I hope this information will be helpful to you.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-02-14.