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OSHA Hazard Communication Letters of Interpretation
OSHA requirements for cleaning chemicals.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: No product endorsement; hazardous-cleaner duties still apply
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its narrow HazCom conclusion remains consistent: OSHA does not approve or endorse a cleaning product, and voluntarily supplying an SDS does not by itself prove that the product is hazardous or nonhazardous.
Under the current HCS, actual hazard classification determines applicable hazard communication. Use manufacturer/importer evaluation, shipped-container label elements and Appendix C, and SDS duties for covered products. The consumer-product exemption (FAQ explanation) is conditional on actual occupational use. The statement about no cleaning-chemical standards should be read in its product-approval context; it does not waive applicable workplace exposure limits, protective measures, or other OSHA standards.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
January 29, 1990
The Honorable Guy Vander Jagt
House of Representatives
Washington, D.C. 20515
Dear Congressman Vander Jagt:
Many of our visitors use these weather-resistant SDS storage boxes like this one. We have 3 different sizes available at Safety Emporium.
This is in response to your letter of December 13 to the Occupational Safety and Health Administration (OSHA) regarding an inquiry on behalf of your constituent, Mr. Joe Huf of Hudsonville, Michigan. In a telephone request to your office, Mr. Huf expressed concern about an apparent product endorsement by OSHA that appears on a all-purpose cleaning product manufactured by a competitor's company.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). The no-endorsement conclusion does not waive duties for hazardous cleaners. Current counterparts: classification, labels, and SDSs.]
According to the product literature forwarded with your letter, the product "3D Supreme Degreaser/Cleaner Concentrate" claims to "meet or exceed OSHA requirements for health and safety. (Material safety data sheets are available)." The Occupational Safety and Health Administration does not set "requirements" for cleaning chemicals. OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS] does, however, require that the hazards of all chemicals produced or imported into the United States be evaluated and that information concerning any associated health or physical hazards be transmitted to employees via comprehensive hazard communication programs. The programs are to include container labeling and other forms of warning, material safety data sheets (MSDS) and employee training.
The product literature you sent us states that "material safety data sheets are available," which would indicate that the chemical manufacturer has performed a hazard determination on the product and has found it to contain hazardous chemicals, since he has produced and has available a MSDS (no MSDS is required if the product does not contain hazardous chemicals). The chemical manufacturer must transmit the MSDS (and appropriate warning labels) to downstream employers with the initial product shipment or whenever there is new hazard information reported on the MSDS. Retail distributors of hazardous chemicals do not have to provide MSDS to commercial customers unless requested to do so (i.e., when retail products are packaged for sale to consumers, no MSDS need be provided unless the product will not be used in the same manner as a normal consumer would use it). OSHA does not prohibit the manufacturer of the product in question from stating that his product "meets OSHA requirements" if he is providing material safety data sheets and hazard information as required under the HCS.
Other OSHA health standards may apply to workplace situations where the product Mr. Huf is concerned about is used. For example, depending on the ingredients contained in the cleaner and it's manner of use, employee protection may be required, including ventilation controls, personal protective equipment, clothing or gloves, or other applicable precautions. This assessment should be made by the employer, again, based on the unique conditions of use of the product at that establishment.
I hope the discussion will be useful to you in responding to your constituent. I am also enclosing a copy of two OSHA booklets on OSHA's Hazard Communication Standard [ILPI: Original HCS 1987 context (PDF) · Current HCS] that may be useful as a further reference source on the requirements of the HCS. Please feel free to contact us again if we can be of further assistance.
Sincerely,
Gerard F. Scannell
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1990-01-29.