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OSHA Hazard Communication Letters of Interpretation

Concerning the conditions under which material data safety sheets are required.

Issued
Record type
Interpretation
Historical standard
1910.1200, 1987 expanded rule (PDF)
Current standard
HCS 2024, as amended

ILPI assessment: U.S. import duties remain; current label elements supersede the old summary

This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains consistent: importing a covered chemical product into U.S. workplaces requires hazard evaluation and communication; a building-code approval is not a substitute for HazCom compliance.

Under the current HCS, apply the importer definition, hazard classification, shipped-container label elements and Appendix C, and SDS duties. Current label contact elements and SDS supplier/emergency contacts differ from the old name/address summary. The foreign manufacturer's assistance does not remove the U.S. importer's applicable responsibilities. Named office contacts and the 1987 enclosure are historical.

Last reviewed: .

Related interpretations
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.