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OSHA Hazard Communication Letters of Interpretation
Requirements for listing multiple exposure limits on MSDSs under the HCS.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Current SDS exposure-limit disclosures are broader
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its distinction between an enforceable OSHA permissible exposure limit (PEL) and a recommended threshold limit value (TLV) remains useful, but the historical most-protective-limit discussion is not the complete current SDS rule. SDS Section 8 calls for OSHA PELs, ACGIH TLVs, and other exposure limits used or recommended by the manufacturer, importer, or employer preparing the SDS, where available.
Do not replace those disclosures with only one selected limit or treat an omitted less-protective OSHA limit as automatically acceptable today. The letter's de minimis enforcement discussion describes its historical facts; it is not a general current waiver. Recommended values do not become enforceable OSHA PELs merely by appearing on an SDS.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 18, 1986
Paul W. Willard, Ph.D.
Manager, Product Regulatory
Toxicology
3M Center
St. Paul, Minnesota 55144
Dear Dr. Willard:
This is in response to your letter of June 25 concerning the requirements for listing multiple exposure limits on material safety data sheets under the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).
It is the intent of the standard that employees and manufacturing users have a fundamental right to know the existing exposure limits of the substances with which they work. OSHA therefore encourages chemical manufacturers and importers to disclose all known exposure limits on the material safety data sheets.
From a compliance standpoint the material safety data sheet must contain the OSHA permissible exposure limit (PEL), and any more protective exposure limit, if one or more exists. Failure to include a less protective exposure limit, other than the OSHA PEL, will be considered a de minimis violation and will not result in the issuance of a citation.
[ILPI note: Current counterpart: SDS Section 8. Its required exposure-limit information is not limited to a single most-protective value. The historical de minimis discussion is not a general current waiver.]
Please feel free to contact us again if further assistance is needed.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
June 25, 1986
Mr. John Miles
U.S. Department of Labor
Occupational Safety and Health Administration
200 Constitution Avenue, N.W.
Washington, DC 20210
Re: MSDS - Exposure Limits
Dear Mr. Miles:
At 3M we have established a policy of placing the most conservative exposure limit and the source, i.e. ACGIH, OSHA, on the Material Safety Data Sheet. We do not customarily list all TLVs, PELs, etc. We believe this practice is prudent, since it is not confusing to those reading the MSDS and does not cloud the primary objective of clear, effective hazard communication and well-founded precautionary information. In addition, this is good practice for averting liability claims.
I understand from Mr. Gibbs that OSHA Region 5 has already adopted this policy. We would like to see acceptance of this policy in all OSHA regions. We are requesting concurrence from Federal OSHA that we are required to designate only one exposure limit which will be the most conservative.
Sincerely,
Paul W. Willard, Ph.D.
Manager, Product Regulatory Toxicology
Diplomat of the American Board of Toxicology
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-08-18.