April 11, 1988

Katherine Davis
Project Industrial Hygienist
International Paper
Suite 212
6075 The Corners Parkway
Norcross, Georgia 30092

Dear Ms. Davis: This is in response to your letter of March 18, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard. Specifically you request a definition of "distributor" and "retail distributor" as used in paragraph 29 CFR 1910.1200(g)(7). The standard at paragraph 29 CFR 1910.1200(c) defines "distributor" as follows: "Distributor" means a business, other than a chemical manufacturer or importer, which supplies hazardous chemicals to other distributors or to employers. A "retail distributor" is a business which supplies hazardous chemicals to the general public, and may also supply hazardous chemicals to other employers. The distribution center that you described in your letter, which sells materials to building contractors and to the general public, therefore, is a "retail distributor" pursuant to 29 CFR 1910.1200(g)(7). If we may be of further assistance, feel free to contact us. Sincerely, Thomas J. Shepich, Director Directorate of Compliance Programs

Mark the locations of your safety equipment and training materials with signs from Safety Emporium.