Letters of Interpretation

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. Each 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.

These letters of interpretation and the standards they address may not apply to OSHA State Plans. State Plans are required to have standards and enforcement programs that are at least as effective as OSHA's and may have different or additional requirements. Please see OSHA-approved State Plans for more information.

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Date Title Standard Number
HCS does not require a particular labeling system's code on the MSDS. 1910.1200
MSDS distribution requirements for chemical manufacturers and importers, distributors and retail distributors. 1910.1200(g)
Applicability of the HCS to office workers and copy machine operators. 1910.1200
Revised Hazard Communication Standard (HCS) Instruction, CPL 2-2. 38B CH-1 1910.1200
Application of the HCS to certain products containing crystalline silica. 1910.1200(b)(2)
Distributor's and retailer's responsibilities for providing MSDSs. 1910.1200(g)
Listing of decomposition products on MSDSs where they are present during normal use or only in the event of a fire. 1910.1200(g)
Labelling requirements for chemicals transported to another plant of the same company under the HCS. 1910.1200(f)
Distributor of health care products would be a "distributor" rather than a "retail distributor" under the HCS. 1910.1200(g)
Applicability of the HCS to crystalline silica, when bound in a polymeric compound and silicone rubber elastomers. 1910.1200
Applicability of the HCS to an employer using portland cement. 1910.1200
Letter to Paul W. Davis from Thomas Shepich concerning requirements of the HCS regarding manufacturer provision of MSDSs with first shipments of hazardous chemicals. 1910.1200
Response to request for OSHA endorsement of a distributor's program for downstream transmittal of MSDSs. 1910.1200(g)
Applicability of the HCS to diesel exhaust emissions and diesel fuel 1910.1200
MSDS distribution responsibilities for chemical manufacturers and importers, distributors and retail distributors. 1910.1200(g)(6)
Hazard determination criteria for corrosive liquids. 1910.1200(d)
Applicability of the Hazard Communication Standard to stevedores in the containerized shipping industry. 1910.1200
Lift trucks or other machines found in the workplace are not containers for labeling requirements of the HCS. 1910.1200(f)
Hazard determination and MSDS requirements under the Hazard Communication Standard (HCS). 1910.1200(d), 1910.1200(g)
Crystalline silica considered a carcinogen under the HCS. 1910.1200