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OSHA Hazard Communication Letters of Interpretation
HCS requirements applicable to oil and gas producers.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Coverage and similar-mixture SDS principle generally retained
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its main HazCom conclusions remain consistent: oil/gas operations have hazard-information duties, and a single SDS may cover qualifying complex mixtures with similar ingredients and hazards. The word “generic” does not permit a sheet that omits actual product hazards.
Under the current HCS, apply similar-mixture SDS conditions, mixture classification, ingredient disclosures, and ready SDS access. See the downstream FAQ and mixture explanation. The stated rollout date, anticipated July 1989 rulemaking, kit prices, and ordering contacts are historical; they do not postpone current duties.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
May 3, 1989
The Honorable David L. Boren
United States Senate
Washington, D.C. 20510
Dear Senator Boren
Many of our visitors use these weather-resistant SDS storage boxes like this one. We have 3 different sizes available at Safety Emporium.
This is in further response to your letter of March 6, addressed to former Assistant Secretary John A. Pendergrass, on behalf of your constituent, Mr. Tom M. Oly, Eagle Resources, Inc., regarding the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS), 29 CFR 1910.1200.
As employers covered by the expanded standard, which took effect for employers on August 1, 1987, oil and gas producers are required to maintain copies of materials safety data sheets for each hazardous chemical in the workplace and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). Crude oil and natural gas meet the standard's definition of hazardous chemicals posing physical and health hazards to exposed individuals. Therefore, oil and gas producers are required to have a material safety data sheet for these substances, as well as for all other hazardous chemicals at your constituent's job sites.
[ILPI note: The August 1, 1987 date appears to be an error. The expanded rule was published August 24, 1987; August 1, 1988 was the later nonmanufacturing programmed-inspection date. See the historical enforcement notice. These dates do not postpone current duties.]
Under the current rule, a "generic" material safety data sheet may address a group of complex mixtures, such as crude oil, which have similar hazards and characteristics because their chemical ingredients are essentially the same, even though the specific composition varies from mixture to mixture.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterpart: similar complex mixtures. A shared sheet must accurately describe the covered products and current hazards, using mixture classification and SDS content requirements.]
Evidence presented during our rulemaking proceeding indicates that availability of hazard information benefits both employers and employees. Employers are required to provide a safe and healthful workplace for employees, and will be able to do a better job when they have information about the potential hazards. Employees will be better able to take steps to protect themselves when they know what the hazards are and how to avoid exposure. The result will be a reduction in chemically-related occupational illnesses and injuries.
It is important to note that OSHA is undergoing further rulemaking to gather additional public comment and information regarding the Hazard Communication Standard's application to the non-manufacturing sector. Among many others, your constituent's national trade association, the Independent Petroleum Association of America, participated in the process and, on December 14, 1987, testified on this issue at public hearings provided by OSHA. A final determination on whether to modify the current rule on this or other issues as a result of the rulemaking record is presently expected in July 1989. Therefore, your constituent's obligations may be affected if changes are made to the standard.
Be sure you're in compliance with DOT placards and labels from Safety Emporium.
OSHA has developed a number of resources to assist employers in complying with the HCS. A kit produced to OSHA is available that provides step-by-step guidance on complying with the requirements of the standard and serves equally well the needs of all employers, regardless of the industry in which they operate. The kit may be purchased through the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C., 20402-9325 at a cost of $18.00. It has a GPO Order No. 929-022-00000-9 and is OSHA 3104, Hazard Communication Kit. It may be ordered by telephone from GPO by calling (202) 783-3238 and using a credit card.
In addition, a booklet entitled, "Chemical Hazard Communication" (copy enclosed) provides employers with an easy-to-read explanation of the responsibilities of employers under the HCS. The booklet also contains a directory of all OSHA Regional and Area Offices. Employers may contact a Regional or Area Office for additional information or assistance.
We hope this information is helpful to you. If we can be of further assistance, please feel free to contact us.
Sincerely,
Alan C. McMillan Acting Assistant Secretary
Enclosure
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1989-05-03.