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OSHA Hazard Communication Letters of Interpretation
Response to request for OSHA endorsement of a distributor's program for downstream transmittal of MSDSs.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Distributor responsibility remains despite use of a service
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its main HazCom conclusion remains consistent: using an association or service to transmit SDSs does not transfer the distributor's compliance responsibility, and an informal review is not OSHA endorsement of a program.
Under the current HCS, apply distributor SDS-transmission duties and the downstream FAQ. Ensure that the required current sheet actually reaches the employer under the applicable shipment, update, and request conditions. Workplace immediate access is a separate obligation, not established merely by hiring a service.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
January 13, 1989
Mr. James L. Fries
Executive Director
American Veterinary Distributors Association
106 West 11th Street
Kansas City, Missouri 64105
[ILPI note: The American Veterinary Distributors Association later became the United Veterinary Services Association.]
Dear Mr. Fries:
This is in regard to your letter of November 18, 1986, regarding a proposed system for downstream transmittal of material safety data sheets as required by the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) 29 CFR 1910.1200. Please accept my apology for the delay in response.
OSHA does not endorse or validate a distributor's program. From an enforcement standpoint, we can determine compliance with the standard only at the time of an inspection. However, we can tell you that after reviewing your proposal, it appears that if the program is implemented as described, it should be successful in meeting the HCS's requirement for providing material safety data sheets to the downstream customers.
As required by the standard, the distributor would be held responsible for ensuring that each customer receives the required material safety data sheet. The distributor, therefore, would be held responsible for violations of the standard and not the American Veterinary Distributors Association.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterpart: distributor SDS duties. An outsourced system must accomplish the required transmittal; it does not itself shift the distributor's responsibility.]
Thank you for your interest in occupational safety and health. If we can be of further assistance, please feel free to contact us again.
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/1989-01-13.