| 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!
OSHA Hazard Communication Letters of Interpretation
Interpretation on availability of emergency information under the Hazard Communication Standard.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: No universal HCS 24-hour rule; disclose contact-hour limits
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its basic HazCom conclusion remains consistent: the HCS does not impose a universal requirement that every SDS emergency number be staffed 24 hours a day. Current SDS Section 1 requires an emergency telephone number; OSHA's current inspection guidance says restrictions on contact hours must be specified and someone at that number must be able to provide more product information.
This is separate from the employer's duty to make SDSs readily accessible during each work shift; an unavailable hotline does not replace workplace access. Also distinguish applicable DOT transportation requirements: PHMSA guidance explains when an emergency number must be monitored at all times hazardous material is in transportation, including incidental storage. The letter is not a waiver of those separate duties.
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.
October 25, 1986
Leo J. Sioris, Pharm.D.
Assistant Managing Director
Minnesota Regional Poison Center
640 Jackson Street
St. Paul, Minnesota 55101
Dear Mr. Sioris:
We have all kinds of safety wall signs at Safety Emporium.
This is in response to your letter of June 9, 1986 concerning the availability of emergency information under the Hazard Communication Standard (HCS), reference 29 CFR 1910.1200.
[ILPI note: The quoted paragraph number and wording are historical. Current counterpart: SDS Section 1; current OSHA guidance addresses restricted contact hours. Separate DOT emergency-number duties may apply during transportation; see the assessment above.]
Your question and our response is as follows:
Question: Do emergency information lines have to be operated 24 hours per day, or for some other specified time period?
Answer: The HCS is primarily written in performance language. Paragraph (g)(2)(xii) of 29 CFR 1910.1200 does not specify hours of operation for emergency information lines.
The Occupational Safety and Health Administration's policy is to resist providing specifications that would erode the intended flexibility of performance standards. The Agency therefore, only provides guidelines to assist employers in fulfilling their responsibilities under the standard.
Chemical manufacturers should consider the following criteria in deciding the hour of operation of their emergency telephone line:
- The completeness of the material safety data sheet for products
- The toxicity/physical hazards of chemicals
- The frequency the chemicals will be used and the immediacy of information needs based on all the above
- Availability of information through other sources
If for example a manufacturer feels that their material safety data sheets are comprehensive and the products present little risk then the emergency number need only be open during normal work hours.
In summary, hours of emergency line operation must be decided individually by each chemical manufacturer.
Please feel free to contact us again if further assistance is needed.
Sincerely,
John B. Miles, Jr., Director
Directorate of Field Operations
September 10, 1986
Mr. Roy Gibbs
Director of Field Operations
Department of OSHA
Washington, D.C. 20210
Dear Mr. Gibbs,
We are enclosing a copy of our letter mailed to Ms. Jennifer Silk on June 9, 1986.
In a follow-up telephone conversation on September 3, 1986, we were informed that she had forwarded our letter to your department for proper interpretation. We would appreciate receiving your clarification of this particular paragraph.
Sincerely,
Leo J. Sioris, Pharm.D.
Assistant Managing Director
June 9, 1986
Ms. Jennifer Silk
Department of OSHA
200 Constitution Ave. NW
Washington, DC 20210
Ref: Hazard Communication Standard (g) Material Safety Data Sheets
(xii) The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.
Dear Ms. Silk:
We would appreciate clarification relative to the time element for answering emergency procedures by telephone for manufacturers, importers, employer or other responsible party preparing or distributing the MSDS.
We are of the opinion that due to the various time zones in the U.S. and the fact that many hazardous chemicals are used by employees on nite-shifts, that telephone calls should be answered on a 24-hour-a-day basis to furnish appropriate emergency information caused by a hazardous chemical exposure. Many manufacturers are assuming compliance by answering these phones during the usual working day (8 a.m. - 5 p.m.). We would appreciate a written response from OSHA regarding this matter.
Thank you for your time.
Sincerely,
Leo J. Sibris, Pharm.D.
Assistant Managing Director
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1986-10-25.