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OSHA Hazard Communication Letters of Interpretation
Solvents classified as a combustible liquid on the basis of the MSDS
- Issued
- Record type
- Interpretation
- Historical HazCom standard
- HCS 1987 expanded rule (PDF)
- Current HazCom standard
- HCS 2024, as amended
ILPI assessment: Supplier reliance retained; use current flammable-liquid categories
Its narrow point remains useful: employers may generally rely on supplier hazard information unless they choose to classify or know contrary information. It does not approve an unidentified solvent for every current use. The letter addresses the obsolete 1987 HCS and its former combustible-liquid terminology.
Under the current HCS, apply supplier/employer classification roles and current flammable-liquid categories, with flash point and other relevant evidence. Separate flammable-liquid requirements also need evaluation. An old MSDS term does not establish a current category or waive controls for actual conditions.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
September 3, 1993
Mr. Andrew Marmaduke,
Regional Environmental Specialist
Safety-Kleen
2727 Paces Ferry Road 2 Paces West,
Suite 1660
Atlanta, Georgia 30339
Dear Mr. Marmaduke:
Store your solvents safely with flammable storage safety cabinets from Safety Emporium.
This is in response to your letter of July 22, and to a telephone conversation with Mr. Ron Davies of my staff, in which you requested a written confirmation from the Occupational Safety and Health Administration (OSHA) that a particular solvent is correctly classified as a combustible liquid on the basis of the information found in the Material Safety Data Sheet (MSDS) attached to your incoming letter.
With reference to 29 CFR 1910.1200(d) [ILPI: Original HCS 1987 context (PDF) · Current HCS; hazard determination replaced by hazard classification] of the Hazard Communication Standard, employers may rely on the information included on a MSDS required by 29 CFR 1910.1200(g) [ILPI: Original HCS 1987 context (PDF) · Current HCS] to determine workplace compliance with OSHA safety and health standards. A product, identified as such on the corresponding MSDS, may be considered a combustible, unless known otherwise by the employer, for example, through his or her evaluation.
[ILPI note: Original HCS 1987 context (PDF) · Current HCS. Use current flammable-liquid criteria and classification responsibilities. The old term “combustible” is not a substitute for a present HCS category or the applicable storage/use rules.]
If we can be of further assistance, please feel free to contact James C. Dillard of my staff, at (202) 219-8031.
Sincerely,
Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1993-09-03-0.