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OSHA Hazard Communication Letters of Interpretation
MSDSs must be distributed to customer with shipment of chemical.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Supplier updates and downstream communication remain required
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its main HazCom conclusion remains consistent: manufacturers/importers must keep hazard information accurate and transmit required updates; employers must turn that information into effective workplace protections.
Under the current HCS, use SDS revision within three months of significant new information, transmission with the required shipment, label revision and new-hazard training. The three-month SDS period is not permission to delay employee protection after a hazard is known. Evaluate sensitization and actual product hazards; keep sheets accessible and procedures appropriate. See downstream context and immediate 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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
June 24, 1994
The Honorable Paul McHale
U.S. House of Representatives
26 East Third Street
Bethlehem, Pennsylvania 18015-1392
Dear Congressman McHale:
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This is in further response to your letter of April 25, requesting information about glutaraldehyde under Occupational Safety and Health Administration (OSHA) regulations. Specifically, your letter asked whether OSHA or other agencies have developed requirements for ensuring that persons exposed to glutaraldehyde are given adequate notice about its potential dangers, particularly where such dangers have been newly discovered.
OSHA's Hazard Communication Standard (29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS]) is designed to ensure that employees are adequately informed of hazards associated with exposure to hazardous chemicals used in the workplace. This standard requires chemical manufacturers and importers to evaluate the hazard potential of chemical products that they manufacture or import, and to disseminate hazard information to downstream distributors and users of those products. Hazard information must be transmitted on Material Safety Data Sheets (MSDSs) that must be distributed to the customer at the time of first shipment of the product. The Hazard Communication Standard also requires that MSDSs be updated by the chemical manufacturer or importer within three months of learning of "new or significant information" regarding the chemical's hazard potential. Therefore, chemical manufacturers and importers have a positive requirement to keep informed of developing hazard information relative to the products that they produce, and to transmit new information with the next shipment of a product made after the MSDS has been updated. The standard also contains specific criteria for defining hazards and for making the hazard determination.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. Current counterparts: three-month SDS revision, required shipment transmission, label updates and new-hazard training. Revision deadlines do not suspend existing worker-protection duties.]
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The Hazard Communication Standard requires all employers (including those in the health care industry) to develop a written hazard communication program that ensures that employees are formally trained in the hazards associated with exposure to chemical agents, and in the methods and procedures designed to protect them from those hazards. It is the employer's obligation under the standard to incorporate any new hazard information transmitted on MSDSs into the hazard communication program.
Thus, the standard requires a "downstream flow of information," which means that producers of chemicals such as glutaraldehyde have the primary responsibility for generating and disseminating hazard information, while users of the chemicals must obtain the information and transmit it to their own employees. When complied with, OSHA believes that the Hazard Communication Standard ensures that employees will be appropriately informed of all chemical hazards present in their workplaces.
We hope this information is helpful, and appreciate the opportunity to be of assistance.
Sincerely,
Joseph A. Dear
Assistant Secretary
cc: Washington, D.C. Office
DEPARTMENT OF LABOR
OFFICE OF THE SECRETARY
EXECUTIVE SECRETARIAT
219-6O19
DOCUMENT CONTROL RECORD
CONTROL NO.: 940011128
DUE DATE: 940531
ORIGINATOR: McHale, Paul (Cong)
ADDRESSED TO: OCIA
ORGANIZATION:
CONSTITUENT:
WH ID NUMBER:
DATE OF LETTER: 940425
SUBJECT: Glutaraldehyde Exposure
ACTION AGENCY: OSHA
DATE ROUTED: 940516
______________ ________________
______________ ________________
______________ ________________
______________ ________________
SIGNATURE LEVEL: APPROP
INFO COPIES TO: Alpha,
REMARKS:
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RETAIN WITH ORIGINAL CORRESPONDENCE
IF THE DUE DATE CANNOT BE MET,
CONTACT
YOUR CORRESPONDENCE UNIT
April 25, 1994
Geri D. Palast
Assistant Secretary
Congressional and Intergovernmental Affairs
Department of Labor
200 Constitution Avenue NW
Washington, D.C. 20210
Dear Ms. Palast:
I recently met with two practicing nurses who have expressed concern about a chemical which they are exposed to at work called Glutaraldehyde.
It is my understanding that Glutaraldehyde is a commonly used sterilization chemical in Gastroenterology (GI) wards. The nurses with whom I spoke work in a GI ward at a hospital in my district. They have told me that, although they have been properly informed through labeling and information sheets as to its potential dangers, there are many people in the medical industry who have not been given adequate notice of newly discovered potential dangers.
I would like to know if the Occupational Safety and Health Administration (OSHA) or any other agencies dealing with Glutaraldehyde have established a way to guarantee that those persons exposed to this chemical are given adequate notice about its potential dangers.
Accordingly, I respectfully request that my concerns be addressed, consistent with applicable law, regulations, and/or agency policy. Please forward your response and any questions you may have to my Staff Assistant, Jennifer Saraceno, in my Bethlehem office. Thank you, in advance, for your attention to my concerns.
Sincerely,
Paul McHale
Member of Congress
PMcH:jls
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1994-06-24-0.