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|Title: 12/05/1988 - MSDS distribution responsibilities for chemical manufacturers and importers, distributors and retail distributors.|
|Record Type: Interpretation||Standard Number: 1910.1200(g)(6)|
December 5, 1988
Mr. Robin W. Grover
Keck, Mahin & Cate
Attorneys at Law
1730 Pennsylvania Avenue, N.W.
Washington, D.C. 20006-4706
Dear Mr. Grover:
This is in response to your letter of September 22, regarding the duties of distributors of products covered by the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) 29 CFR 1910.1200.
In your letter you specifically asked the Agency to respond to two "proposed aspects of compliance by bearing distributors with the Hazard Communication Standard." Our responses are numbered in the sequence in which the questions were posed.
Proposal 1: That chemical manufacturers and importers are required to either provide distributors with one material safety data sheet and label per each product shipped or that they must reimburse distributors for the costs of necessary duplication of material safety data sheets and labels.
Proposal 2: Alternatively, a finding that bearing distributors meet their obligations under HCS by sending a one-time letter (with appropriate updates) to each of their customers containing the information required by the HCS (rather than one material safety data sheet per product shipment).|
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John A. Pendergrass
The official, public domain, OSHA version of this document is available at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=19725&p_text_version=FALSE