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OSHA Hazard Communication Letters of Interpretation
Maintenance of material safety data sheets(MSDS) and the written hazard communication program.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Record access remains; fifteen working days is not the workplace SDS-access rule
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central distinction remains consistent: access to a written HazCom program and retention/access of employee exposure records have requirements separate from immediate workplace SDS access.
Under the current HCS, written-program availability references record-access procedures. Their fifteen-working-day provision includes a delay-notification condition; it does not authorize delaying ready SDS access during the workshift. See the access FAQ. Current exposure-record retention includes a thirty-year rule and specified alternatives/exceptions; retaining every old SDS is not the only permitted method. The 1910.1020 citations below reflect later renumbering of the former 1910.20 record rule.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
July 31, 1989
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Dr. Lynn A. Corson
Civil Engineering Building
Purdue University
West Lafayette, Indiana 47907
Dear Dr. Corson:
This is in response to your letter of May 5, regarding the relationship between the Hazard Communication (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS], and Access to Employee Medical Records, 1910.1020, as they relate to maintenance of material safety data sheets (MSDS) and the written hazard communication program.
The HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] requires the employer to make available the written hazard communication program in accordance with the access to records provisions of 1910.1020. A copy of the written hazard communication program is, therefore, required to be made available upon request to employees, or their designated representative within fifteen working days at no cost to the employee or the representative. The HCS neither requires nor prohibits the printing of pocket-size copies of the program for employees.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). Current counterpart: written-program availability and record access. Do not apply its request timetable to immediate workplace SDS access. The record rule was formerly numbered 1910.20.]
Apart from the requirements of the HCS [ILPI: Original HCS 1987 context (PDF) · Current HCS] regarding the availability of the written hazard communication program, the Access to Employee Medical Records Standard has specific requirements for maintaining MSDSs as employee exposure records. MSDSs, when they indicate a hazard to human health, are specifically defined as employee exposure records in 1910.1020 and are also subject to the access to records provisions of this standard.
We hope this information is helpful to you in clarifying the requirements of these two standards.
Sincerely,
Patricia K. Clark, Acting 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/1989-07-31-0.