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OSHA Hazard Communication Letters of Interpretation
Use of physical versus mailing address of the responsible party listed on the MSDS.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; current U.S. contact requirements apply
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). The address must support contact with a responsible party able to provide hazard and emergency information. OSHA’s 2013 follow-up also discusses the address issue. The historical field number has changed.
Use current SDS Section 1 and label contact information, which specify U.S. contact information. A mailing address does not dispense with the responsible party’s actual ability to answer inquiries. See the current inspection directive’s SDS guidance; do not substitute a foreign-only contact for required U.S. information.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
August 31, 2009
Ms. Peggy Haase
Green Environmental Consulting, Inc.
202 Vanderpool Lane
Houston, TX 77024
Dear Ms. Haase:
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Thank you for your letter of July 7, 2009, to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. You requested a response for your specific question relating to the preparation of material safety data sheets (MSDSs). This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any questions not detailed within your original correspondence. Your question is paraphrased below followed by our response.
Scenario: Your incoming letter indicates that your company prepares MSDSs for a client that contracts out the blending of fuel products at several different locations and that a P.O. Box serves as a centralized location for the chemical manufacturer and, therefore, would be the best address to be included on an MSDS. You correctly noted that 29 CFR 1910.1200(g)(2)(xii) [ILPI: Original HCS 1994 context · Current HCS; contact information now in SDS Section 1] does not address the use of a mailing address versus a physical address. Additionally, you previously contacted an OSHA official, who provided you with a verbal (informal) interpretation that a mailing address alone was not sufficient.
Question: Is a physical or mailing address required on an MSDS?
Reply: The Hazard Communication Standard is a performance-oriented standard. This means that your company has the flexibility to comply with the standard in a way that best fits your business practices and meets the performance requirements for the standard. As you are aware, 29 CFR 1910.1200(g)(2)(xii) [ILPI: Original HCS 1994 context · Current HCS; contact information now in SDS Section 1] states:
The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary. [Emphasis added.]
Either the physical or mailing address of the party listed may be used on the MSDS. The intent of this provision in the standard is to ensure that the party listed can be reached to provide additional information on the hazardous chemicals or clarification of the information on the MSDS, as well as additional emergency procedures, if necessary. We apologize for any confusion our previous response may have caused you.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. The current counterpart is SDS Section 1; the 2013 follow-up addresses the mailing-address question. Required U.S. contact information and a reachable responsible party still matter.]
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Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. 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 the OSHA website at https://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Sincerely,
Richard E. Fairfax, Director
Directorate of Enforcement Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2009-08-31.