| 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
Overwarning on Hazard Labels
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Avoid unsupported warnings; use current classification criteria
This letter addresses the HCS as expanded in 1987, an obsolete version of the Hazard Communication Standard (HCS). Its central warning against indiscriminately labeling every product with every hazard remains useful. However, the old one-positive-study formulation is not the complete current decision rule.
Under the current HCS, determine hazard classification using all relevant evidence and the applicable health/physical criteria, then apply shipped-container label elements and Appendix C. For target-organ effects, consult A.8/A.9 where applicable. Additional label information must not contradict or cast doubt on required hazard information under C.3.
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 27, 1988
MEMORANDUM FOR: MICHAEL G. CONNORS, REGIONAL ADMINISTRATOR
THROUGH: LEO CAREY, DIRECTOR, DIRECTORATE OF FIELD PROGRAMS
FROM: THOMAS J. SHEPICH, DIRECTOR, DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Overwarning on Hazard Labels
This is in response to your memorandum of May 18 on the above subject. Specifically, you wish to know whether it is acceptable under the Hazard Communication Standard (HCS) for a company to use the same comprehensive list of health hazard target organs on the warning labels for an entire line of products.
Acceptability in terms of compliance with the HCS will depend upon whether, in fact, each product possesses all of the listed hazards. Any target organ hazard which is not demonstrated by at least one valid positive study for the chemical which is so labeled is not an appropriate hazard warning.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterparts: classification and label criteria. Retain the accuracy principle; apply current weight-of-evidence and hazard-specific criteria rather than the old study-count shorthand.]
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1988-06-27.