| 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
Training for employees assigned to another employer
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Training arrangements do not remove employer responsibility
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its main conclusion remains consistent: another employer may supply job-specific training, but a contract does not itself establish that employees have received adequate instruction. The supplying employer must assure that the necessary training occurs.
Under the current HCS, apply current information and training requirements and multi-employer coordination. Address the actual job's hazards, controls, SDS access, and labeling. Instruction must match workers' language, literacy, and understanding; see OSHA's training standards policy.
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.
June 16, 1988
Diane H. Hays, R.N.
Occupational Health Nurse
Davis Memorial Goodwill Industries
2200 South Dakota Avenue, N.E.
Washington, D.C. 20018
Dear Ms. Hays:
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 27 requesting information on the training requirements of your employees as required by the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).
The employer has the responsibility to train employees regarding protective practices implemented in their workplace and to explain the labeling system used and how to obtain and use material safety data sheets. Training is crucial to the comprehensive hazard communication program as training explains and reinforces the information presented to employees through the written mediums of labels and material safety data sheets. While the HCS provisions are performance-oriented, the minimum information in 29 CFR 1910.1200(h) must be presented to assure effective employee training concerning the hazards of the particular job assignment.
In view of the above requirements, as a minimum, generic training should be given to all your employees prior to job assignments where they will be or potentially could be exposed to hazardous chemicals. Since your employees are contracted to extended job assignments, directly working under the supervision of the other employer, you can possibly work out a contractual agreement for the other employer to provide the training specific to the hazardous materials used at that job site. It is our recommendation that you actively assure yourself that such training is being provided and is adequate to fulfill your employer responsibilities under the HCS. For your employees, the training program will most likely be the most important component of your hazard communication program because it can be individualized to your employees' abilities. Every effort must be made to train and effectively warn the employees of exposure to hazardous chemicals at the appropriate level of their understanding in view of their special educational requirements.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: current information and training requirements and multi-employer coordination. A contractual arrangement does not eliminate the need to ensure effective workplace-specific training.]
If we can be of further assistance, please 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/1988-06-16-0.