| The Home page of ILPI's Safety Data Sheet (SDS) Resource, the leader in SDS information since 1995! | |
| The history and philosophy behind this resource. | |
| A curated collection of books and reference materials concerning Safety Data Sheets and closely related topics. | |
| Paste your plain text SDS into the SDS-Demystifier, and it will be converted into a hypertext-enriched document with links to detailed explanations of each key term. | |
| An extensive list of frequently asked questions about Safety Data Sheets including regulations, content, compliance, and more. | |
| A humorous take on Safety Data Sheet jargon. Fill in the blanks on our entry form to generate a personalized Unsafety Data Sheet to share with your coworkers. | |
| Since 1995, we've maintained this massive curated list of the best places to find Safety Data Sheets on the Internet. | |
| Way more than a glossary, this hypertext-enhanced resource covers hundreds of SDS-related terms and expert knowledge. Each entry includes both the SDS relevance and links to additional authoritative resources. | |
| Archived results of Safety Data Sheet related polls taken by some of our millions of site visitors | |
| You are here! The OSHA regulations behind SDS regulations, including the inspection guidelines and over 400 official interpretations letters under the Hazard Communication Standard | |
| Commercial suppliers of SDS authoring and management software as well as cloud compliance services. | |
| Commercial companies that will create SDS's for your specific needs as well as SDS translation companies. |
Safety signs, banners, and scoreboards? Get yours at Safety Emporium!
| Title: 03/23/2017 - Hazard Communication Standard's (HCS 2012) June 1, 2016 effective date, 1910.1200(j) | |
| Record Type: Interpretation | Standard Number: 1910.1200(f)(9), 1910.1200(f)(11), 1910.1200(j) |
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.
Mar 23, 2017
Mr. Barry L. Kenyon
Bombardier Transportation [Acquired by Alstom in 2021]
101 Gibraltar Road, Suite 112
Horsham, Pennsylvania 19044
Dear Mr. Kenyon:
Protect your employees with cabinet labels from Safety Emporium.
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 '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 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 ยง 1910.1200(f)(9). 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) 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.
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.