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OSHA Hazard Communication Letters of Interpretation
The employer must provide the 1910.1200 verbal training in a language that is comprehensible.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Comprehensible training requirement remains consistent
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard. Its HazCom conclusion remains consistent with current paragraph (h): employers must provide effective information and training that workers can understand. OSHA's training standards policy also explains that language, vocabulary, and literacy must be taken into account.
An English label or SDS does not remove that duty. The related February 24, 1988 labeling letter addresses the separate requirement to retain English label information, not an exception to comprehensible training. Training should cover current chemical hazards and how to use the workplace's labels/SDSs under paragraph (h)(3); see the SDS FAQ on employer responsibilities.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 10, 1988
Dr. Richard F. Andree
Executive Vice President
Safety & Health Management
Consultants, Inc.
161 William Street
New York, New York 10038
Dear Dr. Andree:
Your employees can stay informed and safety-ready with right to know stations and labels from Safety Emporium.
This is in response to your letter of March 7, regarding the training requirements of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard, 29 CFR 1910.1200.
Specifically, your question is "...if an employer has employees who do not understand verbal English (re: receive work task instructions in a language other than English), must that employer provide the required 1910.1200 verbal training information in a language that is comprehensive?"
Paragraph 29 CFR 1910.1200(h) requires employers to provide employees with information and training on hazardous chemicals in their work area. If the employees that are required to receive this information and training do not comprehend verbal English, the employer must inform and train these employees in a language which is comprehensible in order to satisfy the requirements of 29 CFR 1910.1200(h).
[ILPI note: Current counterpart: effective HazCom training and OSHA's language/vocabulary/literacy policy. The February 24 labeling letter addresses a different duty. At issuance: 1910.1200, 1987 expanded rule (PDF).]
If we may be of further assistance regarding this matter, feel free to contact us.
Sincerely,
John A. Pendergrass
Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1988-04-10.