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OSHA Hazard Communication Letters of Interpretation
Consumer Products that Contain Hazardous Chemicals.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Consumer exemption remains conditional; receipt of a sheet is not the test
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its core conclusion remains consistent when workplace use really matches ordinary consumer use in intended purpose, duration and frequency. It is not a blanket exemption for furniture polish or all products sold to consumers.
Apply the complete consumer-product exemption (FAQ explanation) to actual use. The original cites(b)(2)(ix), but the exemption is(b)(6)(ix). Separate exposure-record definitions and retention/alternative-record conditions must be considered where applicable; not every sheet is automatically a 30-year record, and HCS exemption alone does not decide every recordkeeping question.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
May 28, 1996
[Name Withheld]
Dear [Name Withheld]:
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Thank you for your letter of April 19, addressed to the Honorable Robert Reich, Secretary of Labor, concerning application of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS]). Your letter raised the issue of applying the Hazard Communication Standard to consumer products that contain hazardous chemicals.
Please understand that the Occupational Safety and Health Administration is committed to common sense enforcement of its standards. The scenarios you describe in your letter of consumer product use, such as polishing tables, would not be covered by the Hazard Communication Standard, and therefore, would not require that you maintain a Material Safety Data Sheet (MSDS). Paragraph 1910.1200(b)(6)(ix) [ILPI: Original HCS 1994 context · Current HCS] of the standard (enclosed) exempts hazardous chemicals that are used in a manner, frequency and duration of exposures that are not greater than the range of exposures that could be reasonably experienced by consumers. Also enclosed, is a compliance memorandum that further clarifies the OSHA's position on consumer products.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. This conclusion is limited to the described consumer-equivalent use. The source's(b)(2)(ix) reference should be(b)(6)(ix); see the current consumer-product exemption (FAQ explanation). Separate exposure-record duties depend on their own scope and conditions.]
In regards to your reference to maintaining MSDS for 30 years, our regulation "Access to Employee Exposure and Medical Records (29 CFR 1910.1020)" addresses the requirement to preserve and maintain employee exposure records such as MSDS. However, furniture polish used as described in your letter would not require an MSDS, and consequently, this would not be an issue.
Thank you for your interest in occupational safety and health.
Sincerely,
John B. Miles, Jr., 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/1996-05-28.