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.

February 14, 1986

Mr. A. H. Krieg
Widder Corporation
Great Hill Road
Post Office Box 1069
Naugatuck, Connecticut 06770-1069

Dear Mr. Krieg:

Senator Lowell Weicker, Jr., has asked the Occupational Safety and Health Administration (OSHA) to respond to your letter of December 30, 1985, to him.

Promulgation of the Hazard Communication Standard (HCS) on November 25, 1983, was the culmination of over 10 years of rulemaking activity by OSHA. The standard is based on the premise that employees have a right to know the identities and hazards of the substances to which they may be exposed in their place of employment. This knowledge will ultimately result in a reduction in the occurrence of illnesses and injuries resulting from such exposures.

The major vehicle for informing employees about the hazardous substances to which they may be exposed to is the Material Safety Data Sheet (MSDS). These are written documents that provide extensive information on the chemical identification of components, as well as other useful information such as the hazards of the chemicals and protective measures. MSDS are required for each hazardous chemical in the workplace.

The MSDS for the welding wire that you produce clearly indicates that it contains hazardous chemicals that could affect the health of employees who use it. By providing a MSDS for the welding wire employees will be in a better position to protect themselves from any potential hazards associated with its use.

If you have additional questions regarding the HCS or other OSHA regulations, please feel free to contact our Area Office in Hartford:

Area Director U.S. Department of Labor - OSHA Federal Office Building, Room 508 450 Main Street Hartford, Connecticut 06103

Telephone: (203) 244-2294

I hope this information will be helpful to you.


John B. Miles, Jr., Director
Directorate of Field Operations