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OSHA Hazard Communication Letters of Interpretation
Requirement for MSDSs with hazardous chemicals.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Access/retention principles remain; use the exact alternative-record conditions
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its main HazCom conclusion remains consistent: OSHA is not a central supplier of product SDSs; workplace suppliers and employers have information/access responsibilities. Exposure-record retention is distinct from keeping a current SDS accessible. The access rule was numbered 1910.20 at issuance and is now 1910.1020.
Apply supplier transmission, workplace access and exposure-record access. Under the thirty-year alternative, retaining substance identity alone is insufficient: the record must also say where and when it was used. A current reformulated-product SDS may not describe a 1989 exposure; seek the relevant historical sheet or qualifying records. See the SDS-access FAQ.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
August 28, 1992
The Honorable Michael R. McNulty
Member, United States House of Representatives
U.S. Post Office
29 Jay Street
Schenectady, New York 12305
Dear Congressman McNulty:
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This is in response to your letter of July 24, to the Occupational Safety and Health Administration (OSHA), written on behalf of your constituent Mr. Robert J. Stein, Jr., of Delmar, New York. Mr Stein wrote to you concerning his inability to obtain a Material Safety Data Sheet (MSDS) for a product to which he was exposed in 1989.
Mr. Stein does not indicate whether or not his exposure to the chemical, "Hillyard Extra Strength CSP Cleaner," occurred during workplace operations. Under OSHA's Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS], chemical manufacturers and importers must transmit a MSDS with the initial shipment of a hazardous chemical to the downstream employer(s) to whom they supply the product, and again if the information on the data sheet changes. There is no requirement on the part of manufacturers and importers to provide MSDSs for non-occupational uses, and MSDSs are not required to be sent to OSHA. OSHA does not collect or retain a repository of data sheets; their transmittal to the downstream workplace is solely the responsibility of the manufacturer or importer.
Therefore, if Mr. Stein's exposure came from workplace use of the chemical, he may wish to contact his former place of employment and ask to be provided with a copy of the MSDS for that product. OSHA's "Access to Employee Exposure and Medical Records: standard, 29 CFR 1910.1020, specifically identifies MSDSs as employee exposure records. If the MSDS is the only record of exposure, then the MSDS must be maintained by the employer for at least thirty years. The employer may have retained a record of the formulation of the chemical in lieu of retaining the data sheet, and under 1910.1020 Mr. Stein may obtain this information from his employer.
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). The current alternative retention provision requires identity, where used and when used for at least thirty years. A formulation record alone is not necessarily sufficient. Current workplace SDS access is a separate duty.]
Mr. Stein may also want to contact the manufacturer directly, Hillyard Floor Treatments in St. Joseph, Missouri, to request a copy of the MSDS for the product.
For his reference and for future assistance, Mr. Stein may wish to contact OSHA's Regional Office in New York. The address and telephone number are:
U.S. Department of Labor - OSHA
201 Varick Street - Room 670
New York, New York 10014
Telephone: (212) 337-2371
We hope this information will be helpful to you and your constituent. Please feel free to contact us again if we can be of further assistance.
Sincerely,
Patricia K. Clark, 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/1992-08-28-2.