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OSHA Hazard Communication Letters of Interpretation
Requirements of the Hazard Communication Standard as it applies to the metal chips and other scrap material.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; supplier SDS must fit the scrap
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its central HazCom conclusion remains consistent with the current HCS: hazardous metal scrap requires information to flow to scrap dealers and downstream recipients. A supplier SDS can be passed along when it accurately describes the scrap's hazards; merely copying the bar-stock SDS is not enough if machining, form, contamination, or later use changes the hazards.
Use current classification for known or reasonably anticipated uses, SDS accuracy and updating, and manufacturer/distributor transmittal requirements. Consider dust, fumes, and relevant contaminants. The current scope extends beyond manufacturing workplaces; SIC codes have been superseded by NAICS for industry classification.
The article exemption is not automatic for metal chips or scrap. See the current definition and the SDS FAQ discussion of articles.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
April 8, 1986
Mr. David J. Burch
National Screw Machine Products Association
6700 W. Snowville Road
Brecksville, Ohio 44141
Dear Mr. Burch:
This is in reply to your letter of December 5, 1985 concerning the requirements of the Hazard Communication Standard as it applies to the metal chips and other scrap material as stated in your letter. Please accept my apology for the delay in responding.
You are correct in your understanding that material safety data sheets are required to be supplied to scrap dealers to whom the metal chips and other scrap material are sold. Your members can supply photostatic copies of material safety data sheets to their customers. This is essential so that scrap dealers will be able to pass the information along to their manufacturing customers.
[ILPI note: Current counterparts: SDS accuracy and manufacturer/distributor transmittal. The existing SDS must fit the actual scrap, form, contaminants, and hazards of anticipated use; current coverage is not limited to manufacturing purchasers.]
If we can be of further assistance to you, please do not hesitate to contact us.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
December 5, 1985
Mr. John Miles
Director, Field Operations
USDOL - OSHA
Room N-3603
200 Constitution Ave., N.W.
Washington, D.C. 20210
Dear John:
On Monday, November 25, 1985, I spoke with Mr. David Smith, and later with yourself, to clarify an operational aspect of compliance with the OSHA Hazard Communication Standard (29 CFR Part 1910.1200).
Your employees can stay informed and comply with OSHA regulations with SDS information stations and compliance products from Safety Emporium.
The National Screw Machine Products Association, represents approximately 500 small business metalworking companies who manufacture high precision turned parts from customer specifications.
Parts are produced on automatic screw machines and other turning equipment, typically using steel, stainless steel, brass and aluminum bar stock. The manufacturing process results in substantial quantities of metal chips and other metal scrap.
This scrap material is typically sold to dealers who may or may not perform certain processing operations prior to selling the scrap to metal recyclers.
As a result of my conversations with Mr. Smith and yourself, it is now the understanding of NSMPA that the chips and other scrap material generated by our members' operations are covered by the OSHA Hazard Communication Standard to the extent that our members, and others in the industry, are required to supply material safety data sheets to their scrap dealers.
I was informed that OSHA has taken the position that this scrap material will be considered to have the same characteristics as the original bar stock, since no chemical or other changes to the nature of the material results from the machining process. As a result, both Mr. Smith and yourself indicated that supplying the scrap dealer with a photostatic copy of the material safety data sheet received with the original material shipment complies with the MSDS requirements of the standard.
The NSMPA would greatly appreciate receiving written confirmation from you stating that our understanding of the requirements of the standard, as stated above, are correct.
I also want to offer my thanks for the excellent cooperation, advice and counsel provided by various OSHA personnel during my attempts to clarify this situation for our members. In particular, Mr. Phillip Colleran in the OSHA Region V - Niles, IL office, Mr. Smith, and, of course, yourself, were knowledgeable, considerate and most helpful in helping me develop the information necessary to properly advise our members as to their duties and responsibilities under the Standard.
Cordially,
David J. Burch
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-04-08.