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OSHA Hazard Communication Letters of Interpretation
The paperwork requirement of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Access principle remains; arbitrary SDS format is superseded
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its central HazCom principle remains consistent: workers and employers need reliable hazard information. However, its statement that the standard does not prescribe a specific sheet format is obsolete.
Under the current HCS, use required SDS headings and order, no-information statements, and Appendix D, immediate SDS access (FAQ) and current information and training requirements. The required sixteen headings/order and applicable Appendix D content replace the old free-format approach. Flexibility in organizing a workplace program does not waive mandatory SDS fields or current shipped-label elements.
OSHA marks its matching original corrected 12/6/2024.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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 21, 1994
The Honorable Bob Goodlatte
U.S. House of Representatives
640 Crestar Plaza
10 Franklin Road, S.E.
Roanoke, Virginia 24011
Dear Congressman Goodlatte:
This is in further response to your letter of August 10, on behalf of your constituent Mr. John Reed, regarding the paperwork requirement of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS).
Your constituent's inquiry references a requirement of the HCS for material safety data sheets (MSDS). We have enclosed copies of two booklets designed to assist employers in complying with the HCS, entitled "Chemical Hazard Communication," and "Hazard Communication Guidelines for Compliance." We have also enclosed a copy of the current rule, which was updated in a February 9, 1994 Federal Register notice. The requirements of the HCS have been clarified, but not substantially changed, in this rulemaking notice.
The purpose of the HCS is to ensure that employers and employees have ready access to information regarding the hazards of chemicals used in their workplaces. The HCS only applies to hazardous chemicals. The rule is a "performance oriented" standard that gives employers the flexibility to adapt the rule to the needs of the workplace situation, instead of having to follow specific, rigid requirements.
For each hazardous chemical in the workplace, your constituent is required by the HCS (29 CFR 1910.1200(g) [ILPI: Original HCS 1994 context · Current HCS]) to maintain a copy of the MSDS. As stated above, the rule is performance oriented, establishing what information must be included on the document, but not the specific format in which it must be presented. The MSDS contains valuable information on the hazards of a product, particularly regarding safe handling, clean-up, and first aid procedures.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. This format statement is obsolete. Current required SDS headings and order, no-information statements, and Appendix D specifies the modern SDS structure/content. The general benefits of accessible information remain relevant.]
Evidence presented during our rulemaking proceeding indicates that availability of hazard information benefits both employers and employees. Employers are required to provide a safe and healthful workplace for employees, and will be able to do a better job when they have information about the potential hazards. Employees will be better able to take steps to protect themselves when they know what the hazards are and how to avoid exposure. The result will be a reduction in chemically-related occupational illness and injuries.
We hope this information is helpful. If you have any further questions please contact the Office of Health Compliance Assistance at (202) 219-8036.
Sincerely,
Joseph A. Dear Assistant Secretary
Enclosures: 2 OSHA HAZCOM Booklets, February 9 Federal Register notice
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1994-09-21.