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OSHA Hazard Communication Letters of Interpretation
Requirement of name, address and telephone number on an MSDS.
- Issued
- Record type
- Interpretation
- Historical standard
- 1910.1200, 1987 expanded rule (PDF)
- Current standard
- HCS 2024, as amended
ILPI assessment: Responsible-party principle remains; current Section 1 requires additional details
This letter addresses the obsolete 1987 version of the Hazard Communication Standard (HCS). Its central principle remains useful: the named responsible party must be capable of providing hazard and emergency information, and a consented manufacturer can be the relevant contact. This is not permission to omit applicable current identification or emergency-contact fields.
Under the current HCS, use SDS Section 1 for the name, U.S. address and U.S. telephone number of the manufacturer, importer or other responsible party, plus the emergency phone number. Importers and distributors retain their own applicable duties under (g)(6)/(g)(7) even when another party is designated. An overseas manufacturer's details alone do not satisfy required U.S. contact information. The old paragraph (g)(3)(xii) citation should not be used as the modern location of this requirement.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
September 13, 1993
Ms. Leslie C. Birnbaum
Corporate Health and Safety Manager
Wehran EnviroTech
666 East Main Street
Middletown, New York 10940
Dear Ms. Birnbaum:
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Thank you for your letter of July 23, concerning requirements of the Occupational Safety and Health Administrations (OSHA) Hazard Communication Standard (HCS). You specifically inquired "whose name, address, and telephone number must appear on the MSDS?" Your question pertains to the HCS (29 CFR 1910.1200 [ILPI: Original HCS 1987 context (PDF) · Current HCS]) paragraph (g)(3)(xii) [ILPI: Original HCS 1987 context (PDF) · Current HCS; contact information now in SDS Section 1] which states:
[ILPI note: At issuance: 1910.1200, 1987 expanded rule (PDF). The current counterpart is SDS Section 1, including the required U.S. contact information and emergency phone number. The old field citation is historical; responsible-party designation does not eliminate other supplier obligations.]
"The name, address, and telephone number of the chemical manufacturer, importer, employer, or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary."
We concur with your reading of the standard. Responsible parties must be able to supply all the information required by the MSDS, including the appropriate emergency information. Generally this will be the manufacturer or importer. If the chemical manufacturer has consented to being designated the responsible party and they are capable of providing the necessary information then the requirement of the standard has been met.
Thank you for your interest in occupational safety and health.
Sincerely,
Ruth E. McCully, Director Office of Health Compliance Assistance
July 23, 1993
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Mr. Roger Clark
Occupational Safety and Health Administration
Director of Compliance Program
Room 3469
200 Constitution NW
Washington, D.C. 20210
Dear Mr. Clark:
On July 9, 1993, we called the OSHA Office of Compliance to obtain a regulatory interpretation of the Hazard Communication Standard [ILPI: Original HCS 1987 context (PDF) · Current HCS] for one of our clients. At the time, we spoke with Mr. Tom Galassi who advised us to submit the question to the Office for a response.
Therefore, we would appreciate a response regarding a regulatory interpretation to the issue described below in relation to the Hazard Communication standard.
Our client purchases paper from a paper manufacturer. Subsequently, our client puts their name on the paper and distributes it as their product. The issue that has arisen from this procedure is whose name, address and telephone number must appear on the MSDS?
In discussing this issue with Mr. Galassi, he believed that as long as the chemical manufacturer was comfortable in responding to the distributors clients, there is no need for our client to place their name on the MSDS. Additionally, it is our understanding as per 29 CFR 1910.1200(g)(3)(xii) [ILPI: Original HCS 1987 context (PDF) · Current HCS; contact information now in SDS Section 1] that the name, address and telephone of the company whose name appears on the MSDS must be capable of supplying an inquirer with additional information on the chemical hazards and/or emergency response information. It is our thought that the manufacturer would be in a better position to supply this information than the distributor in this specific case.
We would appreciate a response to this inquiry at your earliest convenience. Thank you.
Sincerely,
WEHRAN-NEW YORK, INC.
Leslie C. Birnbaum
Corporate Health and Safety Manager
LCB/dm
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1993-09-13-1.