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OSHA Hazard Communication Letters of Interpretation
Material safety data sheet requirement of the Hazard Communication Standard.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Responsible party must be able to supply meaningful hazard information
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains consistent: naming another responsible party on an SDS is not permission to provide only superficial information or an ineffective contact.
Under the current HCS, use the responsible-party definition and SDS Section 1 identification and emergency telephone requirements. The old general name/address/telephone discussion is not the full modern checklist. See accuracy and updating and shipped-label contact elements.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 28, 1989
Mr. J. W. Kleinschmidt
Clevite Elastomers
33 Lockwood Road
Milan, Ohio 44846
Dear Mr. Kleinschmidt:
Your employees can stay informed and safety-ready with right to know stations and labels from Safety Emporium.
This is in response to your letter of February 21, addressed to Ms. Jennifer Silk, regarding a material safety data sheet (MSDS) requirement of the Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS].
The situation as described by you in your letter, where the contact telephone number on the MSDS is a party other than the product manufacturer and only able to provide "basic information" is not within the intent of the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS]. The standard requires that the MSDS contain the name, address and telephone number of the party who prepares or distributes the MSDS. Generally, this will be the manufacturer or importer. If the preparer or distributor of the sheet is a party other than the manufacturer or importer, i.e., an employer or other responsible party, their name, address and telephone number may be listed on the MSDS. The HCS does allow a responsible party to be named on the MSDS. However, in all cases, the party listed must be able to provide additional information on the hazardous chemicals, or clarification of the information on the MSDS, as well as, additional emergency procedures, if necessary, in lieu of the manufacturer.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: responsible-party definition and SDS Section 1. Listing an alternate party does not remove the need for meaningful hazard and emergency information.]
The Agency will assist you in obtaining a properly completed MSDS for the product. The information you provided has been forwarded to OSHA's Office of Field Programs for further action.
We appreciate the opportunity to address you concern. If we can be of further assistance, please do not hesitate to contact us.
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/1989-07-28-0.