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OSHA Hazard Communication Letters of Interpretation
Hazard Communication Standard's (HCS 2012) June 1, 2016 effective date, 1910.1200(j)
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Core employer duties remain useful; implementation dates are historical
The letter distinguishes an employer’s existing stock from a supplier’s current shipments. Maintain labels or replace them immediately with a permitted workplace system under paragraph (f)(9) and paragraph (f)(6), retain the latest received SDS and provide effective training.
The old implementation dates are historical. Current significant-information updates and SDS access still matter; this is not permission to ignore newly known hazards. Replacing a working MSDS with a new SDS is separate from exposure-record retention.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
Mar 23, 2017
Mr. Barry L. Kenyon
Bombardier Transportation
101 Gibraltar Road, Suite 112
Horsham, Pennsylvania 19044
Dear Mr. Kenyon:
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Thank you for your letter to the Occupational Safety and Health Administration (OSHA). Your letter was referred to OSHA 's Directorate of Enforcement Programs for a response. Your question is in regards to OSHA 's Hazard Communication Standard [ILPI: Original HCS 2012 context · Current HCS] 's (HCS 2012) June 1, 2016 effective date. This letter constitutes OSHA 's interpretation only of the requirements herein, and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased question and our response follow below.
Question: What are the end-user requirements to have a label and safety data sheet (SDS) for a chemical (5-year shelf life) packaged and shipped prior to June 1 and December 1, 2015, respectively?
Response: End users (i.e., employers) with existing stock or who have received shipped containers of hazardous chemicals with HCS 1994 [ILPI: Original HCS 1994 context · Current HCS] labels and material safety data sheets (MSDSs) (even after the June 1, 2016 final effective date) are allowed to maintain and use those containers with HCS 1994 labels and MSDSs. The end user must not remove or deface any labels (including HCS 1994 labels) on chemical containers, unless the end user immediately marks the containers with workplace labeling. See 29 CFR § 1910.1200(f)(9) [ILPI: Original HCS 2012 context · Current HCS]. If an end user receives HCS 2012 labels from an upstream supplier for its existing stock, it is advisable to affix the HCS 2012 label over the HCS 1994 label, although it is not required. In addition, paragraph (f)(11) [ILPI: Original HCS 2012 context · Current HCS] requires employers who become aware of any significant information regarding the hazards of a chemical to revise the labels within six months of becoming aware of the new information. When an end-user receives a compliant HCS 2012 SDS, it must replace the MSDS for the corresponding hazardous chemical. The end-user is also responsible for training its workers regarding the new label elements.
[ILPI note: At issuance: HCS 2012. Use current significant-information updates, SDS access and training. The letter’s HCS 2012 implementation dates do not create a new shipping extension.]
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA 's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA 's interpretation of the requirements discussed. From time to time, letters are affected when the agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA 's website at http://www.osha.gov. If you have further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Sincerely,
Thomas Galassi, 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/2017-03-23-2.