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OSHA Hazard Communication Letters of Interpretation
Hazard Communication Standard (HCS) Material Safety Data Sheet Requirements for the Construction Industry.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: No barriers to immediate employee access remains the governing principle
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains consistent: construction employees need usable SDS information at their jobsite without barriers to immediate access. Electronic access is acceptable only when it works for the employees who need it.
Under the current HCS, apply workplace SDS access, multi-employer coordination, and current information and training requirements. The absence of a fixed number of minutes does not authorize delay, permission requirements, or an unusable system. The SDS FAQ explains immediate access and electronic-system safeguards. The limited traveling-employee alternative has its own emergency-access condition.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
August 7, 1989
MEMORANDUM FOR: MICHAEL G. CONNERS , REGIONAL ADMINISTRATOR
THROUGH: LEO CAREY, DIRECTOR, DIRECTORATE OF COMPLIANCE PROGRAM
FROM: PATRICIA K. CLARK, ACTING DIRECTOR, DIRECTORATE OF COMPLIANCE PROGRAMS
Your employees can stay informed and comply with OSHA regulations with SDS information stations and compliance products from Safety Emporium.
SUBJECT: Hazard Communication Standard (HCS) Material Safety Data Sheet Requirements for the Construction Industry.
This is in response to your memorandum of May 26, requesting an interpretation of the HCS material safety data sheet (MSDS) requirements as it applies to the construction industry.
MSDSs are required to be maintained at the jobsite. The basis for this interpretation is the HCS definition of workplace which means "establishment, jobsite, or project, at one geographical location containing one or more work areas." The MSDSs must be on the jobsite and readily accessible to employees when they are in their work areas during the workshift. Alternatives, to actual paper copies of MSDSs, which provide readable copy on-site are permitted to meet this requirement this requirement. For example, computer terminals or FAX machines which allow employees to read and refer to the MSDS are permitted to be maintained at the jobsite, in lieu of paper copies, as long as no barriers to access exist.
There are no minimum time requirements for determining whether MSDSs maintained at the jobsite are readily accessible to employees while they are in their work areas. To make this determination compliance officers must ascertain whether a barrier to access exists. For example, must employees ask a supervisor or other management representative for the MSDS; are the sheets or alternative methods maintained at a location and under conditions where employees can refer to them during each workshift, when they are in their work areas; if a computer or FAX system is used, do employees know how to operate and obtain information from the system? Employees must have access to the MSDSs and be able to get the information when they need it. This may be accomplished in many ways and requires the compliance officer to exercise professional judgment in evaluating the accessibility of the MSDSs on-site.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). The current rule expressly prohibits barriers to immediate employee access. No numerical time limit is a permission to delay; see the ready-access FAQ.]
On multi-employer jobsites, employers who produce, use or store hazardous chemicals, must provide copies of MSDSs to the employers of other employees exposed to the hazardous chemicals, or make them available at a central location at the jobsite. Again, actual paper copies of data sheets, computer terminal access, or other means of providing readable copy on-site are permitted.
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1989-08-07-0.