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OSHA Hazard Communication Letters of Interpretation
Hazard communication in construction - general contractor responsibilities.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Employer roles and knowledge still govern multi-employer enforcement
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its core HazCom conclusion remains useful: a general contractor can have responsibilities at a multi-employer site, but citation depends on the applicable duties, role and knowledge rather than its title alone.
Use current multi-employer methods, current information and training requirements and OSHA's Multi-Employer Citation Policy. Evaluate creating, exposing, correcting and controlling roles as applicable. The old Field Operations Manual chapter reference is not a current navigation guide. The referenced January 29, 1990 letter supplies historical context. Historical enforcement context: original CPL 2-2.38C (October 22, 1990). Current counterpart: current HCS inspection procedures.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
June 10, 1991
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MEMORANDUM FOR: LINDA R. ANKU, REGIONAL ADMINISTRATOR
FROM: PATRICIA K. CLARK, DIRECTOR, DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Hazard Communication in Construction - General Contractor Responsibilities
This is in response to your memos of March 11 and May 8 regarding the enforcement of the Hazard Communication Standard (HCS) [ILPI: Original HCS 1987 context (PDF) · Current HCS] on construction sites. You specifically requested clarification on situations where the general contractor on a construction site may be responsible for or cited for violations of the HCS.
As explained in our letter to Senator Bentsen of January 29, 1990, and in CPL 2-2.38C [ILPI note: Original: CPL 2-2.38C (October 22, 1990). Current counterpart: CPL 02-02-079.] (see pages 21-22 and pages A-14 through A-18), the Agency's citation policy for hazard communication violations at multi-employer worksites is no different than for violations of any other OSHA standard. The Field Operations Manual, Chapter V., Section F., "Multi-Employer Worksites," also gives specific guidance on the Agency's citation policies and states, at V.F.1.b. that: "It must be shown that each employer to be cited has knowledge of the hazardous condition or could have had such knowledge with the exercise of reasonable diligence. (See Chapter IV, B.1.b.(4)."
We believe this guidance is applicable to the situations raised in your memoranda. Please feel free to contact Melody Sands of my staff (FTS: 523-8036) if you have any further questions.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: multi-employer coordination and Multi-Employer Citation Policy. Actual duties, employer role and knowledge must be established.]
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1991-06-10-0.