Interactive Learning Paradigms, Incorporated


The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995!
The history and philosophy behind this resource.
A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics.
Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term.
An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more.
A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers.
Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet.
Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources.
Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors
You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard
Commercial suppliers of SDS authoring and management software as well as cloud compliance services.
Commercial companies that will create SDS's for your specific needs as well as SDS translation companies.

Safety signs, banners, and scoreboards? Get yours at Safety Emporium!


Title: 10/25/1986 - Interpretation on availability of emergency information under the Hazard Communication Standard.
Record Type: InterpretationStandard Number: 1910.1200(g)(2)(xii)

October 25, 1986

Leo J. Sioris, Pharm.D.
Assistant Managing Director
Minnesota Regional Poison Center
640 Jackson Street
St. Paul, Minnesota 55101

Dear Mr. Sioris:

First Aid wall sign

We have all kinds of safety wall signs at Safety Emporium.

This is in response to your letter of June 9, 1986 concerning the availability of emergency information under the Hazard Communication Standard (HCS), reference 29 CFR 1910.1200.

Your question and our response is as follows:

Question: Do emergency information lines have to be operated 24 hours per day, or for some other specified time period?

Answer: The HCS is primarily written in performance language. Paragraph (g)(2)(xii) of 29 CFR 1910.1200 does not specify hours of operation for emergency information lines.

The Occupational Safety and Health Administration's policy is to resist providing specifications that would erode the intended flexibility of performance standards. The Agency therefore, only provides guidelines to assist employers in fulfilling their responsibilities under the standard.

Chemical manufacturers should consider the following criteria in deciding the hour of operation of their emergency telephone line:

  1. The completeness of the material safety data sheet for products
  2. The toxicity/physical hazards of chemicals
  3. The frequency the chemicals will be used and the immediacy of information needs based on all the above
  4. Availability of information through other sources

If for example a manufacturer feels that their material safety data sheets are comprehensive and the products present little risk then the emergency number need only be open during normal work hours.

In summary, hours of emergency line operation must be decided individually by each chemical manufacturer.

Please feel free to contact us again if further assistance is needed.

Sincerely,

John B. Miles, Jr., Director
Directorate of Field Operations


September 10, 1986

Mr. Roy Gibbs
Director of Field Operations
Department of OSHA
Washington, D.C. 20210

Dear Mr. Gibbs,

We are enclosing a copy of our letter mailed to Ms. Jennifer Silk on June 9, 1986.

In a follow-up telephone conversation on September 3, 1986, we were informed that she had forwarded our letter to your department for proper interpretation. We would appreciate receiving your clarification of this particular paragraph.

Sincerely,

Leo J. Sioris, Pharm.D.
Assistant Managing Director


June 9, 1986

Ms. Jennifer Silk
Department of OSHA
200 Constitution Ave. NW
Washington, DC 20210

fume hood label
Ensure safety in your workplace with laboratory labels and signs from Safety Emporium.

Ref: Hazard Communication Standard (g) Material Safety Data Sheets

(xii) The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.

Dear Ms. Silk:

We would appreciate clarification relative to the time element for answering emergency procedures by telephone for manufacturers, importers, employer or other responsible party preparing or distributing the MSDS.

We are of the opinion that due to the various time zones in the U.S. and the fact that many hazardous chemicals are used by employees on nite-shifts, that telephone calls should be answered on a 24-hour-a-day basis to furnish appropriate emergency information caused by a hazardous chemical exposure. Many manufacturers are assuming compliance by answering these phones during the usual working day (8 a.m. - 5 p.m.). We would appreciate a written response from OSHA regarding this matter.

Thank you for your time.

Sincerely,

Leo J. Sibris, Pharm.D.
Assistant Managing Director


The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-10-25.