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OSHA Hazard Communication Letters of Interpretation
Position on MSDS format for compliance with the Hazard Communication standard.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Format and coverage advice superseded
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its central advice that employers may choose any MSDS format, using the twelve information categories listed below, should not be followed under the current HCS. Paragraph (g)(2) specifies SDS section numbers, headings and their order, and Appendix D specifies the information required. The headings for Sections 12–15 must be present in order, although OSHA does not enforce their information requirements.
The letter's limitation to manufacturing-sector purchasers (SIC codes 20–39) is also obsolete. Apply the current scope and application, including its exceptions, and SDS distribution requirements. The basic obligation for chemical manufacturers and importers to prepare an SDS for each hazardous chemical continues in paragraph (g)(1); that does not preserve the historical freedom of format or manufacturing-only scope.
OSHA source correction: OSHA's original page is marked “Corrected 1/29/2009” and replaces the historical staff contact below. No letter-specific withdrawal or supersession notice was observed on that page as of this review. The historical name, telephone number and address below should not be used for current inquiries.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
MARCH 4, 1985
Richard Homik, Supervisor
Occupational Safety & Hygiene
Sherritt Gordon Mines, Ltd.
Metal and Chemical Division
Fort Saskatchewan, Alberta, Canada TSL 2P2
Dear Mr. Homik:
This is in response to your letter of February 11 requesting information on the adequacy of your firm's planned MSDS format for compliance with the OSHA Hazard Communication and Labelling standard.
Your employees can stay informed and safety-ready with right to know stations and labels from Safety Emporium.
To begin with, the regulatory philosophy of the Reagan Administration is to provide the business community with maximum flexibility with respect to how compliance with regulatory objectives is achieved. Toward that end, OSHA is phasing out the use of the Form 20 which previously served as a format for MSDS sheets. We are not planning to prescribe any fixed format, nor are we in a position to review and approve the formats selected by the various companies required to issue MSDS's pursuant to the Hazard Communication standard.
[ILPI note: At issuance: original 1983 rule (PDF). Current counterpart: paragraph (g)(2) and Appendix D prescribe the SDS section structure and content. The historical freedom to choose any format no longer applies.]
However, the standard requires chemical manufacturers and importers to develop an MSDS for each hazardous chemical they produce (or if they are US importers) for products they import. These must be supplied, updated, and provided to purchasers in SIC codes 20-39 which comprises the manufacturing sector.
[ILPI note: SIC (Standard Industrial Classification) codes have been superseded by the North American Industry Classification System (NAICS). The manufacturing-only scope is obsolete. See current scope and application and SDS distribution.]
In order to assist you in reaching a decision on the final format of your firm's MSDS, I can provide you with a 12 item list drawn from the standard itself which comprises the information categories that must be reflected in the MSDS. Of course firms are free to format an MSDS any way they want, and to include additional information as well. The following categories of information must be included:
- Product identity
- Physical and chemical characteristics
- Physical hazard
- Health hazard
- Routes of entry or exposure
- Exposure limits
- Carcinogenicity potential
- Precautions for handling and use
- Applicable control measures
- Emergency and first aid procedures
- Date of preparation and or change
- Preparer and where additional information may be obtained
[ILPI note: This twelve-item list is historical, not a current SDS checklist. Use the section numbers and headings in paragraph (g)(2) and the content requirements in Appendix D.]
We in OSHA appreciate the care and concern your firm has evidenced in preparing to work with us to implement this important standard. I hope this information will prove helpful to you. If you have any additional specific concerns about the Hazard Communication and Labelling standard you can direct them to our staff expert on this subject Ms. Jennifer Silk, phone (202) 523-7166, mailing address Room N3636, 200 Constitution Avenue, N.W., Washington, D.C. 20210.
[ILPI note: OSHA corrected this contact on January 29, 2009, substituting the Office of General Industry Enforcement at (202) 693-1850. That is the correction recorded by OSHA, not a verification of current contact details; use the local OSHA office directory for current guidance.]
Sincerely,
Gary Strobel
Special Assistant to the Assistant Secretary
for Occupational Safety and Health
FEBRUARY 11, 1985
Mr. Gary Strobal
Room S 2316
200 Constitution Ave., N.W.
Washington, D.C. 20210
U.S.A.
Dear Gary:
As per our recent telephone conversation, please find enclosed a copy of our current Material Safety Data Sheet which we use for our products in Canada. Could you please review our MSDS format and let me know if it will comply with the OSHA requirements that are scheduled for November, 1985. If the format does meet the MSDS requirements, we intend to use this sheet to accompany product shipments to the U.S.
I would appreciate your comments in writing if possible. My business card is enclosed if immediate contact is required.
Thank you for your concerns on this matter.
Yours truly,
Dick Homik
Supervisor
Occupational Health & Hygiene
Sherritt Gordon Mines Limited
Fort Saskatchewan, Alberta, Canada
T8L 2P2
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1985-03-04.