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OSHA Hazard Communication Letters of Interpretation
Material Safety Data Sheet Requirements Under the Hazard Communication Standard.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Optional-format and omitted-section policy is superseded
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its permission to omit an entire MSDS topic because information is unavailable does not describe current SDS requirements. Current SDSs must follow required SDS headings and order, no-information statements, and Appendix D.
Required headings and subheadings must not simply disappear; where no relevant information is found, indicate that fact as required. OSHA requires the headings for Sections 12–15 but does not enforce their information content because those areas are outside its jurisdiction. See the SDS FAQ on format and content.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
May 12, 1988
MEMORANDUM FOR:
BRUCE HILLENBRAND, DIRECTOR, Directorate of Federal-State Operations
FROM: THOMAS J. SHEPICH, DIRECTOR, Directorate of Compliance Programs
SUBJECT: Clarification of Interpretation on Material Safety Data Sheet Requirements Under the Hazard Communication Standard
Ms. Barbara Bryant, of your staff, has brought to our attention a concern that was raised during the February meeting of the Occupational Safety and Health State Plan Association held in Chapel Hill, North Carolina. The concern has to do with a past interpretation (copy attached) made by this Directorate regarding leaving off a section on a material safety data sheet (MSDS) when the pertaining information does not exist. Some OSHA personnel have mistakenly interpreted this policy to apply only to computer generated MSDS.
It was and still is our policy that the interpretation applies to any type of MSDS. Since the standard is performance-oriented and no MSDS format is specified, employers are free to develop MSDSs that are designed for a specific chemical. For example, if an employer develops a MSDS for a chemical which is not a carcinogen, a space addressing carcinogenicity does not have to be provided on the form.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This optional-format policy has been superseded by required SDS headings and order, no-information statements, and Appendix D. A noncarcinogenic product does not justify removing the required toxicological-information structure.]
If you have any questions, please feel free to contact Steve Simon on 523-8036.
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1988-05-12-0.