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.

December 5, 1994

Mr. Sidney L. Earnest Aiken Builder's Supply Co., Inc. 156 Williamsburg Street, N.E. Aiken, South Carolina 29801

Dear Mr. Earnest:

Congressman Butler Derrick forwarded your letter of August 15 to the Occupational Safety and Health Administration (OSHA) concerning OSHA's hazard communication requirements for the wood products you sell. In that letter, you express concern over the burden associated with providing Material Safety Data Sheets (MSDS's) for wood products to your customers.

Your responsibilities as a retail distributor under the amended Hazard Communication Standard (HCS) are limited. Specifically, section 1910.1200(g)(7)(iii) requires a retail distributor to post a sign or otherwise inform their customers that MSDSs are available and to provide an MSDS to a customer only upon request; you are not obligated under the standard to provide a copy of the MSDS to each customer, unless requested by the customer to do so.

The amendments to the standard with respect to wood products reflect a clarification of OSHA's intent in the original standard; the amended standard does not impose new or additional requirements. Wood and wood products are still exempted from the hazard communication standard if the only hazard presented from use of the product is flammability or combustibility, which are hazards that are well-known among users of wood products. However, it may not be generally known among users that inhalation of certain types of wood dust or chemicals used to treat wood can present a serious lung disease hazard. For this reason, OSHA has always required under the hazard communication standard that distributors of wood products provide MSDS to employers whose employees may be exposed to these inhalation hazards.

We hope this clarifies your understanding of your obligations under the hazard communication standard. If you have additional questions, please feel free to contact OSHA's Office of Health Compliance Assistance at (202) 219-8036.


Joseph A. Dear Assistant Secretary