| 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
Definition of "distributor" and "retail distributor" as used in paragraph 29 CFR 1910.1200(g)(7).
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Definitions generally consistent; apply current distribution conditions
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its distinction between a distributor and a retailer remains useful. The current distributor definition still distinguishes these suppliers from manufacturers/importers. A business selling hazardous chemicals both to the public and to employers can have retail-distributor duties.
Under the current HCS, apply the complete distributor and retail SDS provisions, including their commercial-account, request, notification, and upstream-information conditions. The retail label alone does not determine every SDS duty; see the downstream discussion in the SDS FAQ.
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 11, 1988
Katherine Davis
Project Industrial Hygienist
International Paper
Suite 212
6075 The Corners Parkway
Norcross, Georgia 30092
Dear Ms. Davis:
We have all kinds of safety wall signs at Safety Emporium.
This is in response to your letter of March 18, regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard. Specifically you request a definition of "distributor" and "retail distributor" as used in paragraph 29 CFR 1910.1200(g)(7).
The standard at paragraph 29 CFR 1910.1200(c) defines "distributor" as follows:
"Distributor" means a business, other than a chemical manufacturer or importer, which supplies hazardous chemicals to other distributors or to employers.
A "retail distributor" is a business which supplies hazardous chemicals to the general public, and may also supply hazardous chemicals to other employers. The distribution center that you described in your letter, which sells materials to building contractors and to the general public, therefore, is a "retail distributor" pursuant to 29 CFR 1910.1200(g)(7).
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: distributor definition and retail/distributor SDS duties. Apply the full current conditions rather than treating the retail description as an exemption.]
If we may be of further assistance, feel free to contact us.
Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1988-04-11.