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OSHA Hazard Communication Letters of Interpretation
Applicability of the Laboratory Standard; MSDS and labeling requirements.
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 1994, pre-GHS archive
- Current standard
- HCS 2024, as amended
ILPI assessment: Coverage principles remain; old label elements and optional SDS format are obsolete
This letter addresses the obsolete 1994 version of the Hazard Communication Standard (HCS). The distinction between laboratory use and production-related quality control remains relevant. Laboratory coverage depends on all applicable criteria, not the room's name. Shipping hazardous chemicals to customers still creates supplier duties.
Consult the Laboratory Standard and HCS laboratory provisions. Modern shipped labels require the prescribed elements, and SDSs require the specified headings/order and Appendix D content. The historical three-item label list and freedom to choose any MSDS format are no longer complete guidance.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
May 28, 1999
Ms. Maricela Carter
Baker Hughes; Baker Petrolite
Safety Programs
3900 Essex Lane
Houston, TX 77027
Dear Ms. Carter,
We have received your September 15, 1998 letter to Richard Fairfax, Director, Occupational Safety and Health Administration (OSHA) Directorate of Compliance Programs (DCP), in which you asked questions regarding the classification of your laboratory under the Hazard Communication Standard (HCS), 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS], or the Chemical Hygiene Standard, 29 CFR 1910.1450 [ILPI: Original 1990 laboratory-rule notice · Current Laboratory Standard]. Your inquiry can be summarized into two questions, which are outlined below.
1. Do our laboratories (including quality assurance laboratories) fall under the Chemical Hygiene Standard (29 CFR 1910.1450) or the Hazard Communication Standard (29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS])?
The best way to approach this question is to provide you with further information to allow you to make this determination, as we are not familiar with your work processes. Laboratories considered quality control/quality assurance laboratories are classified as adjuncts of production operations and are not covered under the Laboratory Standard, but are covered under the HCS. For those laboratories covered under the Laboratory Standard, the requirements of the HCS are superseded, and the Laboratory Standard takes precedence. Laboratories covered under the Laboratory Standard are those which use or handle hazardous chemicals in which all of the following conditions are met:
- Chemical manipulations are carried out on a "laboratory scale"
- Multiple chemical procedures or chemicals are used,
- The procedures involved are not part of a production process, nor in any way simulate a production process, and
- Protective laboratory practices and equipment are available and in common use to minimize the potential for employee exposure to hazardous chemicals.
The Laboratory Standard does not apply to laboratory use of hazardous chemicals which provide no potential for employee exposure. Examples of these would be the use of test media such as "dip and read" tests or commercially prepared pregnancy tests.
2. Can Baker Petrolite supply its customers with a contact sheet or label stating formulation ID, date formulated, contact person, phone, address, storage and handling information, and warning information (instead of a formal MSDS)?
Baker Petrolite is directly responsible for providing MSDSs and labels which meet all the requirements of the HCS. Containers of chemicals which meet the definition of a hazardous chemical under the standard must be labeled with:
- the identity of the chemical,
- appropriate hazard warnings, including the target organ effects, and
- the name and address of the chemical manufacturer, importer, or other responsible party.
MSDSs must contain all of the required information in paragraph (g) of the standard, 29 CFR 1910.1200 [ILPI: Original HCS 1994 context · Current HCS], Material Data Safety Sheets. Although there is no required format for presenting hazard information, we have included a sample MSDS form which you might find helpful.
[ILPI note: At issuance: HCS 1994, pre-GHS archive. HCS 2012 introduced mandatory SDS headings and order and standardized shipped-label elements. The optional-format statement is historical; use current paragraph (g)(2), Appendix D and paragraph (f)(1).]
Thank you for your inquiry and we hope you find this information useful. If you require further assistance, please do not hesitate to call the Office of Health Compliance Assistance at (202) 693-2190.
Sincerely,
Richard Fairfax
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/1999-05-28-0.