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OSHA Hazard Communication Letters of Interpretation
Labeling and 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: Identifiable responsible party remains required; modern contact elements apply
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains useful: anonymous letter codes do not replace required supplier/responsible-party identification, and altering required information can create responsibility for its accuracy.
Under the current HCS, apply responsible-party definition, shipped-label contact information, and SDS Section 1. Current labels include the name, U.S. address and U.S. telephone number of the manufacturer, importer or other responsible party; SDS Section 1 has supplier and emergency-contact requirements. The old name/address discussion is not a complete modern checklist. See accuracy and updating and distributor duties.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
July 6, 1989
[Name Withheld]
Dear [Name Withheld]:
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This is in response to your letter of February 8, addressed to Mr. Thomas J. Shepich, regarding labeling and material safety data sheet (MSDS) requirements under the Hazard Communication Standard (HCS), 29 CFR 1910.1200. Please accept my apology for the delay in response.
Your first issue deals with the "responsible party." According to the HCS, the "responsible party" means someone who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary. This definition applies to chemical manufacturers, importers, and distributors. If your client wishes to list the name, address, and emergency telephone number of the actual manufacturer, the designation of "manufacturer" rather than "responsible party" must be used for clarity.
Regarding your second issue on labeling, the standard specifically requires the name and address of the chemical manufacturer, importer or other responsible party to be identified on the label. Replacing this information with an "A", "B", or "C" is not acceptable on containers leaving the workplace. The label information, in some situations, provides the only identifying and hazard information to employees handling the chemical. Also, employers that do not receive the MSDS with the initial shipment must request one from the chemical manufacturer or distributor. The label again provides the only identifying information.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: label contact information and SDS identification/emergency contact. Required current contact elements cannot be replaced by anonymous letter codes.]
In all cases, the "responsible party" named on the MSDS and the label is held responsible for the accuracy of the information and potentially subject to citation if a violation of the HCS was determined to exist. If the distributor makes changes to the required information on the labels and the MSDSs, the distributor then assumes responsibility.
We hope we have adequately addressed your client's concerns. We apologize for any inconvenience caused by the delay in response. If you need further assistance, please do not hesitate to contact us again.
Sincerely,Patricia K. Clark, Acting 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/1989-07-06.