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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How to Request a Letter of Interpretation

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Date Title Standard Number
Hazard Communication Standard (HCS) Labeling Requirements for Industrial Thermometers 1910.1200
Clarification of the label requirements of the OSHA Hazard Communication Standard (HCS). 1910.1200(f)
The hazard warning labels attached to shipments of solder. 1910.1200
Labeling and material safety data sheet requirements under the Hazard Communication Standard. 1910.1200
Application of the Hazard Communication Standard to prescription drug products. 1910.1200
Interpretation of the HCS as it relates to laboratories and requirements with respect MSDSs. 1910.1200
HCS requirements applicable to oil and gas producers. 1910.1200
Consumer product exemption under the OSHA Hazard Communication Standard (HCS). 1910.1200(a)(4)(iv)
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