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.

September 7, 1995

Mr. Jeffrey M. Carter
Director of Safety
M.J. Moran, Inc.
Mechanical Contractors
4 South Main Street
Haydenville, MA 01039

Dear Mr. Carter:

This is in response to your letter of July 11 requesting a letter of compliance from the Occupational Safety and Health Administration (OSHA) regarding your "HAZCOM" data sheets to be utilized at the worksite to provide clear information of the chemicals used by your employees.

Your approach to developing supplemental HAZCOM data sheets that modify the Material Safety Data Sheets (MSDS) to convey pertinent, clear, and concise information to your employees meets the intent of the Hazard Communication Standard (29 CFR 1926.59). Please understand that employees would still require ready access to complete MSDS and you may wish to state that on the "HAZCOM" data sheets.

If we can be of any further assistance please contact Tom Galassi in the Office of Health Compliance Assistance at (202) 219-8036.

Sincerely,



Roy F. Gurnham, P.E., J.D.
Director
Office of Construction and Maritime
Assistance