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OSHA Hazard Communication Letters of Interpretation
Interpretation of 1910.1200 - Clarification on effective date of SDSs replacing MSDSs
- Issued
- Record type
- Interpretation
- Historical standard
- HCS 2012 (historical)
- Current standard
- HCS 2024, as amended
ILPI assessment: Generally consistent; implementation dates are historical
The central advice remains useful: maintain the most recent sheet received and make it accessible under paragraph (g)(1) and paragraph (g)(8). This is not a universal requirement for an employer to author a new SDS merely because only an old MSDS is available. See the January 31, 2013 orphan-product letter and missing-SDS FAQ.
The 2015 dates describe HCS 2012 implementation, not current deadlines; use paragraph (j) for current implementation dates. Replacing a working copy does not automatically authorize discarding exposure records subject to 1910.1020 retention rules.
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This comparison with current requirements is not a finding that OSHA has formally withdrawn this letter.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.
Jun 13, 2014
Mr. Ross Olsby
M3V Data Management
11925 East 65th Street
Indianapolis, Indiana 46236
Dear Mr. Olsby:
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Thank you for your letter to the Occupational Health and Safety Administration's (OSHA) Directorate of Enforcement Programs. You requested guidance on replacing material safety data sheets (MSDSs) with newer safety data sheets (SDSs) under OSHA's revised Hazard Communication Standard, 29 CFR 1910.1200 (HCS 2012 [ILPI: Original HCS 2012 context · Current HCS] ). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your questions have been paraphrased, followed by our response.
Question: When is an employer required to replace their MSDS collection with revised SDSs in order to be in compliance with HCS 2012 [ILPI: Original HCS 2012 context · Current HCS]? Would OSHA take enforcement action against employers who only have an MSDS available to employees?
Response: OSHA's final rule modifying the Hazard Communication Standard (HCS) [ILPI: Original HCS 2012 context · Current HCS] was issued on March 26, 2012, and it became effective on May 25, 2012 [77 FR 17574-17896]. Under 1910.1200(j)(2) [ILPI: Original HCS 2012 context · Current HCS; historical HCS 2012 implementation dates], manufacturers, importers, and distributors must be providing SDSs (instead of MSDSs) for all shipments of hazardous chemicals to employers and downstream customers by June 1, 2015. SDSs may be provided before this date; however, for any shipment of chemicals after June 1, 2015, an SDS in the required 16-section format must be provided.
All employers, per 1910.1200(g)(1) [ILPI: Original HCS 2012 context · Current HCS] and 1910.1200(g)(8) [ILPI: Original HCS 2012 context · Current HCS], must have, maintain, and make available to employees the most recent MSDS or SDS received from a chemical manufacturer, importer, or distributor for each hazardous chemical in the workplace. If the employer is not maintaining the most current MSDS or SDS received, then enforcement action may occur. However, OSHA would not issue citations for maintenance of MSDSs when SDSs have not been received. As OSHA explained in the January 31, 2013, letter to Mr. Joel Gregier employers may, but are not required to, contact manufacturers or distributers of products they have previously ordered to request new SDSs, and under 1910.1200(g)(6)(iv) [ILPI: Original HCS 2012 context · Current HCS], the SDSs must be provided.
[ILPI note: At issuance: HCS 2012. Keep the latest received sheet accessible under paragraph (g)(8). Historical MSDS retention and current-use access are separate from exposure-record retention.]
Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2100.
Sincerely
Thomas Galassi, Director
Directorate of Enforcement Programs
The original official public domain version of this document is available from OSHA at https://www.osha.gov/laws-regs/standardinterpretations/2014-06-13.