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 http://www.osha.gov.

May 1, 1989

Mr. Nelson C. Holly Safety Administrator Certaineed Corporation Kansas City, Kansas 66115

Dear Mr. Holly:

This is in response to your letter of October 31, 1988, requesting that HMIS and NFPA labeling information be included on the material safety data sheet.

The preamble to the Hazard Communication Standard (HCS) recognizes the existence of numerous labeling systems that are currently in use in industry. Many of the systems rely on numerical or alphabetical codes to convey the hazards. Although, the intent of the standard is to permit the use of these systems for inplant labeling, provided the entire hazard communication program is effective, the Occupational Safety and Health Administration (OSHA) does not endorse specific services or products. It would, therefore, be inappropriate for OSHA to require a particular labeling system's code on the material safety data sheet.

We hope this information is helpful to you in clarifying your concern. If we can be of further assistance, please feel free to contact us.


Thomas J. Shepich, Director Directorate of Compliance Programs