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OSHA Hazard Communication Letters of Interpretation
HCS does not require a particular labeling system's code on the MSDS.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: No mandatory private code; distinguish modern shipped and workplace labels
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its narrow conclusion remains consistent: the HCS does not require an HMIS or NFPA rating on an SDS and OSHA does not endorse a specific commercial labeling service.
Under the current HCS, the SDS must contain the required headings/content and Appendix D information. HMIS/NFPA ratings may supplement communication but do not replace shipped-container label elements and Appendix C. A workplace system must satisfy paragraph (f)(6) with effective current information and training requirements. HMIS/NFPA severity numbers must not be equated with HCS hazard-category numbers.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 1, 1989
Mr. Nelson C. Holly
Safety Administrator
Certaineed Corporation
Kansas City, Kansas 66115
Dear Mr. Holly:
This is in response to your letter of October 31, 1988, requesting that HMIS and NFPA labeling information be included on the material safety data sheet.
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The preamble to the Hazard Communication Standard (HCS) recognizes the existence of numerous labeling systems that are currently in use in industry. Many of the systems rely on numerical or alphabetical codes to convey the hazards. Although, the intent of the standard is to permit the use of these systems for in-plant labeling, provided the entire hazard communication program is effective, the Occupational Safety and Health Administration (OSHA) does not endorse specific services or products. It would, therefore, be inappropriate for OSHA to require a particular labeling system's code on the material safety data sheet.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: workplace labels and shipped labels with Appendix C. Private rating systems may supplement required information, but are not substitutes for modern shipped-label elements.]
We hope this information is helpful to you in clarifying your concern. If we can be of further assistance, please feel free to contact us.
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/1989-05-01.