| 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
Hazardous Materials Identification System labels and the HCS
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, original 1983 rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: HMIS workplace use remains possible; shipped labels require more
This letter addresses the original 1983 Hazard Communication Standard (HCS), which is now obsolete. Its allowance for HMIS as part of an effective workplace program remains relevant under workplace-label alternatives. The system must convey the required hazard information and be understood through employee information and training; it is not automatically acceptable simply because it uses a familiar name or numerical rating.
The old suggestion to add target-organ effects and manufacturer information is not the complete current shipped-label rule. Apply shipped-container label requirements and Appendix C. See the HyperGlossary discussion of HMIS and hazard classification; workplace rating numbers should not be confused with HCS hazard categories. The historical CPL instruction is not a current product approval; current enforcement counterpart: current HCS inspection procedures.
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.
May 21, 1987
Mr. J. Andrew Doyle
Counsel
National Paint & Coatings Association
1500 Rhode Island Avenue, N. W.
Washington, D.C. 20005
Dear Mr. Doyle:
Keep informed about workplace hazards with proper labeling techniques and safety posters available from Safety Emporium.
This is in response to your letter of April 21 regarding the acceptability of the National Paint and Coatings Association's Hazardous Materials Information System (HMIS) for use in meeting the in-plant labeling requirements of the Hazard Communication Standard.
[ILPI note: At issuance: original 1983 rule (PDF). Current counterparts: workplace alternatives and shipped labels with Appendix C. HMIS alone does not supply all current shipped-label elements. The cited 1986 CPL is historical; current enforcement counterpart: HCS inspection procedures.]
As you mention in your letter, page A-11 of Occupational Safety and Health Administration Instruction CPL 2-2.38A CH-1 states that "the intent of the standard is to permit the use of (numerical labeling systems) as long as the entire Hazard Communication Program is effective." Therefore, the use of the HMIS would be acceptable in meeting the in-plant labeling requirements of the standard. Of course, the system's user would need to correctly use the system (apply the correct numerical ratings) to be found in compliance.
In the case of shipped containers, a label must include the target organ effects. This information may be part of an additional label or added to the HMIS label. Also, in the case of shipped containers, the label must include the name and address of the chemical manufacturer, importer, or other responsible party.
If we can be of further assistance, please feel free to contact us again.
Sincerely,
Frank White
Deputy Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1987-05-21.