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OSHA Hazard Communication Letters of Interpretation
The purpose of Material Safety Data Sheets.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Hazard-information purpose remains; modern SDS content and exceptions apply
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). Its central conclusion remains useful: SDSs convey chemical hazards and protective measures, and suppliers may also voluntarily issue sheets for products outside mandatory HCS coverage.
Under the current HCS, apply scope and exemptions, required SDS headings and order, no-information statements, and Appendix D, accuracy/update duties and immediate SDS access (FAQ). Supplier transmission under (g)(6)/(g)(7) includes applicable shipment and request conditions; an initial/updated-shipment summary is not exhaustive. A voluntary sheet alone does not prove a product is covered or nonhazardous; actual hazard classification and use govern.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
January 25, 1995
The Honorable James A. Barcia
House of Representatives
Suite 502 301 East
Genesee Saginaw, Michigan 48607
Dear Congressman Barcia:
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Thank you for your letter of October 13, concerning an inquiry from your constituent, Mr. Jerome Bouverette, related to the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS [ILPI: Original HCS 1994 context · Current HCS]). Mr. Bouverette requested clarification of the purpose of Material Safety Data Sheets (MSDSs), which are required to be developed and distributed under the HCS.
MSDSs are specified by section 1910.1200(g) [ILPI: Original HCS 1994 context · Current HCS] of the HCS (enclosed). The MSDS lists the hazardous ingredients of a product, its physical and chemical characteristics (e.g. flammability, explosive properties), its effect on human health, the chemicals with which it can adversely react, handling precautions, the types of measures that can be used to control exposure, emergency and first aid procedures, and methods to contain a spill. When new regulatory information, such as exposure limits, or new health effects information becomes available, the MSDS must be updated to reflect it.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. Current counterparts: SDS accuracy/significant-new-information updates and required SDS headings and order, no-information statements, and Appendix D. Employee access and required supplier transmission remain separate obligations.]
Employers and employees need the information contained on MSDSs to protect themselves from hazardous chemical exposures and to work safely with chemical products. The result will be a reduction in chemical source illness and injuries in the workplace. Since the HCS became effective, the use and distribution of MSDSs have proven to be an effective and efficient way to ensure that employers and employees can obtain necessary information on the hazards associated with exposure to chemicals in the workplace.
It should also be noted that MSDSs are only required for hazardous chemicals. In reality, MSDSs are prepared and provided for many products that are not covered by the HCS. It is our understanding that this is being done for product liability purposes, not for compliance with any Federal regulation. In fact, MSDSs were prepared and made available by many producers prior to implementation of regulatory requirements. In addition, many customers request MSDSs on all products, whether they are hazardous or not. This practice has also encouraged producers to provide MSDSs for non-hazardous products. While OSHA does not require or encourage this practice, we certainly do not have the authority to prohibit producers from distributing such MSDSs.
We hope this information is helpful to you. Please contact OSHA's Office of Health Compliance Assistance at (202) 219-8036 if you have any additional questions.
Sincerely,
Joseph A. Dear Assistant Secretary
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/1995-01-25-0.