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OSHA Hazard Communication Letters of Interpretation
The Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard as they apply to veterinary drugs.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Drug distinctions remain; apply every current exemption category
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its principal HazCom conclusions remain consistent: FDA labeling is a label-only exemption, while solid-final-form drugs have a separate exemption. The occasional-crushing qualification remains important.
Under the current HCS, apply complete current drug exemption, FDA/USDA label exemption and OSHA's pharmacy guidance. The drug exemption also addresses manufacturer-packaged retail drugs and employee personal consumption; the final paragraph's solid-dose shorthand is not an exhaustive list. Nonexempt hazardous veterinary preparations require accurate hazard classification, SDSs and current information and training requirements. Current state guidance: Minnesota State Plan.
OSHA marks its matching original corrected 12/6/2024.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
December 22, 1993
C.M. Stowe, VMD, PhD.
Wendt Professional Laboratories
100 Nancy Drive
Box 128
Belle Plaine, Minnesota 56011
Dear Dr. Stowe:
Thank you for your letter of December 10 concerning the requirements under the Occupational Safety and Health Administration's (OSHA) Hazardous Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS] as they apply to veterinary drugs.
The standard does not apply to nonhazardous drugs, but any drug that meets the criteria of a hazardous chemical in the HCS generally would be covered. The HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] contains some exemptions that would apply to some drug and veterinary products. Section (b)(5)(ii) of the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS; now 1910.1200(b)(5)(iii)] states that drugs that are subject to labeling requirements by the Food and Drug Administration (FDA) under the Federal Food, Drug and Cosmetic Act are exempt from the labeling provisions of OSHA's Hazard Communication Standard. Please note that this section of the HCS exempts only labeling requirements and does not exempt the other requirements of the standard such as providing Material Safety Data Sheets (MSDS).
Another section of the standard that is relevant to your situation is 1910.1200(b)(6)(viii) [ILPI: Original HCS 1987 context (PDF) · Current HCS; now 1910.1200(b)(6)(vii)] which exempts from coverage under the standard drugs as defined by the Federal Food, Drug and Cosmetic Act that are in solid final form, ready for direct administration to the patient such as tablets, capsules or pills. If these drugs are not in final form in that they are designed to be dissolved or crushed by employees prior to administration, then they are covered by the HCS. (There may be situations where a tablet, capsule or pill is dissolved or crushed for purposes of administration when that is not generally the way it is dispensed. The final form exemption would apply in this situation.) Consequently, MSDS are required to be prepared and transmitted with the initial shipment of all hazardous chemicals including drug and veterinary products, except for products which are in solid final form for direct administration to patient.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Read this summary with the complete current drug exemption, including its retail and personal-consumption categories. FDA labeling alone does not waive all other duties; occasional administration-related crushing remains qualified as explained above.]
As you may be aware, the Occupational Safety and Health Act of 1970 allows states to assume responsibility for their own occupational safety and health plans, which are approved and monitored by Federal OSHA. The Minnesota Department of Industry and Labor operates such a plan. As a condition of plan approval, States are required to adopt and enforce standards that are either identical to, or at least as effective as, the Federal standards. Therefore, this response may differ from that which would be given by the State of Minnesota. For information regarding the requirements of Minnesota standards, you may want to contact:
Minnesota Department of Labor and Industry
443 Lafayette Road
St. Paul, Minnesota 55155
Telephone: (612) 296-2342
We hope this information is helpful. If you have any further questions please contact us at (202) 219-8036.
Sincerely,
Roger A. Clark, Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1993-12-22.