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.

NOTICE:

How to Request a Letter of Interpretation

Filters


Date Title Standard Number
Requirements for including a manufacturer's occupational exposure limit (OEL) on a material safety data sheet (MSDS). 1910.1200, 1910.1200(g)(2)(i)(C)(1), 1910.1200(g)(2)(vi)
OSHA Training Standards Policy Statements 1910.134(k), 1910.147(c), 1910.1030(g), 1910.1200(h), 1926.21
Using the Globally Harmonized System (GHS) to Comply with OSHA's Hazard Communication Standard. 1910.1200, 1910.1200(f)
Use of physical versus mailing address of the responsible party listed on the MSDS. 1910.1200, 1910.1200(g)(2)(xii)
Application of OSHA PEL for nitric oxide as 8-hr TWA to pregnant employees. 1910.1000, 1910.1200, 1910.1200(e), 1910.1200(f), 1910.1200(g), 1910.1200(h)
Alleged deficiencies on an MSDS for one of Icynene's insulation products. 1910.1200(g), 1910.1200(g)(2)
Alleged deficiencies contained on a material safety data sheet (MSDS) for a spray-on insulation product (the Icynene Insulation System). 1910.1200, 1910.1200(g)(1), 1910.1200(g)(2)
Requirements for labeling products that contain a nitrate or nitrite. 1910.1200, 1910.1200(b)(6)(ix), 1910.1200(f)(1)(i)
Requirements of the HCS and the employer's ability to rely on a manufacturer's hazard determination. 1910.132(d)(1), 1910.1200(g)(5), 1910.1200(h)
Whether written programs may be kept solely in an electronic format. 1910.146(c)(4), 1910.1030(c)(1)(i), 1910.1030(c)(1)(iii), 1910.1200(e)(1), 1910.1200(e)(4)
Requirements for labels and material safety data sheets for distributors of lumber. 1910.1200, 1910.1200(b)(6)(iv), 1910.1200(f)(2)(i), 1910.1200(g)(7)(iii)
Chemical manufacturer's responsibility with regard to inorganic arsenic under OSHA's Hazard Communication Standard. 1910.1018, 1910.1018(a), 1910.1018(b), 1910.1018(p)(3), 1910.1200, 1910.1200(b)(2), 1910.1200(c)
Storage and use of compressed gas cylinders; whether cylinder is considered an oxidizing compressed gas or oxygen cylinder. 1910.101, 1910.101(a), 1910.101(b), 1910.1200, 1910.1450
Clarification of the requirement to provide accurate and current hazard information on an MSDS. 1910.1200, 1910.1200(g)(2)(xi)
Request to provide list of corrosive materials and concentrations requiring use of emergency eyewashes and showers. 1910.132(d), 1910.133(a)(1), 1910.151(c)(1), 1910.1200(c), 1910.1200(g), 1926.50(g)
Requirement for employer to assess potential hazards of handling trailer debris to provide necessary PPE and hazard communication information to affected employees. 1910.120(q), 1910.132, 1910.134(a)(2), 1910.1200
Manufacturer and distributor requirements for developing MSDS for hazardous products. 1910.1200, 1910.1200(d)
MSDS requirement for occupational use of cosmetic Gentian Violet. 1910.1200, 1910.1200(b)(5)(iii), 1910.1200(b)(6)(viii), 1910.1200(b)(6)(ix)
Use of generic MSDSs written by third-party companies and employer responsiblities when using an online MSDS service. 1910.1200, 1910.1200(g), 1910.1200(g)(2)
Responsibility of chemical manufacturers and importers to provide MSDSs to one or more establishments owned and managed by same employer. 1910.1200, 1910.1200(g)(6)(i)