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Dec 22, 1992 - Updated material safety data sheets. Dec 22, 1992 - Updated material safety data sheets.

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OSHA Hazard Communication Letters of Interpretation

Updated material safety data sheets.

Issued: December 22, 1992
Record type: Interpretation
Historical standard: 1910.1200, 1987 expanded rule (PDF)
Current standard: HCS 2024, as amended

ILPI assessment: Supplier responsibility and employee access remain; OSHA does not distribute product SDSs

This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central HazCom conclusion remains consistent: manufacturers/importers/distributors supply required product SDSs, and OSHA does not operate a replacement-sheet distribution service.

Use SDS accuracy/updates, manufacturer/importer duties, distributor duties and workplace access. A supplier request does not itself establish immediate employee access; see the downstream and SDS-access FAQ. For missing required sheets, use the current OSHA office directory in the assessment disclosure. OSHA marks its original corrected March 19, 2009.

Last reviewed: October 27, 2026.

Related interpretations

Clarification of the requirement to provide accurate and current hazard information on an MSDS. (April 18, 2008)
SDS dates, accuracy and responsibility for updating newly known hazards.
Employers responsibilities under HCS 2012 to classify hazards and create SDSs for products whose manufacturers are no longer in business. (January 31, 2013)
Orphan products and unavailable suppliers do not automatically transfer SDS-authoring duties to every employer.
Hazard Communication Standard's (HCS 2012) June 1, 2016 effective date, 1910.1200(j) (March 23, 2017)
Existing employer stock is distinguished from a supplier’s current shipments and newly known hazards.
Requirements of the HCS and the employer's ability to rely on a manufacturer's hazard determination. (December 22, 2008)
Supplier reliance does not allow an employer to disregard relevant hazards it discovers during use.

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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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

December 22, 1992

[Name Withheld]

Dear [Name Withheld]

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This is in response to your inquiry of October 28, concerning the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard, 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS].

You requested that OSHA send you updated material safety data sheets (MSDSs) for the products listed in your letter. The Hazard Communication Standard (HCS) requires manufacturers, importers and distributors to send MSDSs with initial shipments to all downstream users, for any item that would expose employees to hazardous chemicals. OSHA does not provide MSDSs to employers. We suggest that you contact the manufacturer or distributor of the products listed in your letter to request updated MSDSs.

[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: supplier transmission, distributor duties and employee access. Request the correct product's current sheet from its supplier; unresolved required-SDS failures may be referred to the local OSHA office.]

If the manufacturer or distributor will not send you an MSDS, you may contact your OSHA area office for enforcement action:

US Dept. of Labor - OSHA
639 Granite Street, 4th Floor
Braintree, Massachusetts 02184
(617) 565-6924

We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.

Sincerely,

Ruth Mc[C]ully, Director
Office of Health Compliance Assistance

This hypermarked and content-enhanced page is copyright by ILPI, all rights reserved. Unauthorized duplication or posting on other web sites is expressly prohibited. For questions, comments and concerns, please contact us at our SDS email address.

The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1992-12-22-0.