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.

January 13, 1989

Mr. James L. Fries
Executive Director
American Veterinary Distributors
106 West 11th Street
Kansas City, Missouri 64105

Dear Mr. Fries:

This is in regard to your letter of November 18, 1986, regarding a proposed system for downstream transmittal of material safety data sheets as required by the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (HCS) 29 CFR 1910.1200. Please accept my apology for the delay in response.

OSHA does not endorse or validate a distributor's program. From an enforcement standpoint, we can determine compliance with the standard only at the time of an inspection. However, we can tell you that after reviewing your proposal, it appears that if the program is implemented as described, it should be successful in meeting the HCS's requirement for providing material safety data sheets to the downstream customers.

As required by the standard, the distributor would be held responsible for ensuring that each customer receives the required material safety data sheet. The distributor, therefore, would be held responsible for violations of the standard and not the American Veterinary Distributors Association.

Thank you for your interest in occupational safety and health. If we can be of further assistance, please feel free to contact us again.


Thomas J. Shepich, Director
Directorate of Compliance Programs