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OSHA Hazard Communication Letters of Interpretation
Interpretation of the HCS as it relates to laboratories and requirements with respect MSDSs.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Narrow received-SDS principle retained; full laboratory duties still apply
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its narrow statement about retaining received SDSs remains reflected in the HCS laboratory provision. It is not a general statement that all laboratories have no duty to obtain hazard information, train employees, or prepare an SDS when shipping chemicals.
This letter predates the 1990 Laboratory Standard. Determine whether 1910.1450 laboratory scope applies, including its information/training and hazard-identification duties. Otherwise apply the appropriate HCS coverage. Under the current laboratory shipping provision, laboratories shipping hazardous chemicals have manufacturer/distributor label and SDS duties. A room called a laboratory is not automatically within every limited provision.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 5, 1989
Mr. Dennis P. Johnson
Staff Industrial Hygienist
Kerr-McGee Corporation
Kerr-McGee Center
Oklahoma City, Oklahoma 73125
[ILPI note: Kerr-McGee was acquired by Anadarko in 2006; Anadarko was subsequently acquired by Occidental Petroleum. This corporate-history note is ILPI commentary, not part of the original letter.]
Dear Mr. Johnson:
Your chemical reactions can be run safely and effectively with US-made clamps and other laboratory accessories from Safety Emporium.
This is in response to your letter of November 28, 1988, and a follow-up to your telephone conversation with Mrs. Jennifer Courtney of my staff, in which you requested an interpretation of the Hazard Communication Standard (HCS), 29 CFR 1910.1200, as it relates to laboratories and our requirements with respect to material safety data sheets (MSDS). Please accept my apology for the delay in this written response.
The HCS addresses laboratories in a more limited fashion than it does for other types of establishments. An employer is only required to maintain those MSDS which the supplier sends. There is no affirmative obligation for a laboratory to request or otherwise procure data sheets.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). This is a narrow interpretation of the HCS received-SDS provision, not a waiver of other laboratory duties. Current counterparts: HCS laboratory provisions and Laboratory Standard 1910.1450 (adopted after this letter). Shipping hazardous chemicals has additional label/SDS requirements.]
We appreciate the opportunity to address your concerns. Please do not hesitate to contact us again if you have further questions.
Sincerely,
Patricia K. Clark, Acting DirectorDirectorate of Compliance Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1989-06-05.