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OSHA Hazard Communication Letters of Interpretation
Copies of MSDSs and the written hazard communication program must be provided to an employee representative.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Access principle retained; copying charges have exceptions
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its core access principle remains relevant: employees and designated representatives can obtain the required written hazard communication program and qualifying exposure records. Training videos are not automatically part of that written program.
Under the current HCS, apply written-program access and SDS access. Qualifying SDS exposure records fall under 1910.1020(c)(5)(iii). The record rule was numbered 1910.20 when this letter was issued; OSHA's copy uses its current number.
The statement that later copies may be charged for is incomplete without the current copying rules and exceptions, including free initial access and protections concerning revised records and initial requests by a recognized or certified collective bargaining agent. See the SDS FAQ on employer responsibilities.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
June 30, 1988
Mr. Richard D. Montgomery
Director Safety and Security
Fruehauf Corporation
10900 Harper Avenue
Detroit, Michigan 48213
Dear Mr. Montgomery:
This is in response to your letter of May 27. You have raised two specific questions
Question 1: Is an employer expected to provide, at no cost, a copy of all material safety data sheets to a representative of his/her employees?
Answer: A material safety data sheet is defined as an employee exposure record under OSHA regulation 29 CFR 1910.1020. Whenever an employee representative places an initial request for an exposure record, 1910.1020(e) requires that the employer either
- provide a copy of the record without cost;
- make available mechanical copying facilities;
- loan the record for a reasonable period of time.
An employer may charge administrative costs for a second and any subsequent request for the same record by the same employee group.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Read this with current copying-cost rules and exceptions. Not every repeat-related request may be charged. The historical standard number was 1910.20, later renumbered 1910.1020.]
Question 2: Is an employer required to provide a copy of the Hazard Communication Program, and if so, does this include training aides such as video tapes?
Answer: The Hazard Communication Standard at 1910.1200(e)(4) requires that the employer make the written hazard communication program available, upon request, to employees and their designated representatives. Audio-visual training aides are not part of the written program and therefore are not subject to this requirement.
I hope that this information is helpful to you. If I can be of further assistance, please feel free to contact me again.
Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1988-06-30.